Finding Text
Federal Agency: U.S. Department of the Treasury
Federal Program Name: State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Period: 3/3/2021 – 12/31/2026
Compliance Requirement: Procurement – Suspension and Debarment
Type of Finding:
* Significant Deficiency in Internal Control over Compliance
* Other Matters
Criteria or Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: The City’s documentation of their search for suspension and debarment did not include the date the search was performed and therefore it was not possible to determine that the search was performed prior to the date of procurement.
Questioned Costs: None
Context: While performing audit procedures, it was noted that City management did not maintain documentation of the date that the search for suspension and debarment was performed and that it was prior to finalizing the procurement.
Cause: The City did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement.
Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance.
Repeat Finding: 2022-002
Recommendation: We recommend that the City review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable.
Views of Responsible Officials: There is no disagreement with the audit finding.