M anagements Response/Corrective Action Plan:
The City of Sault Ste. Marie has instituted the following measures to remedy this deficiency to be implemented immediately.
1. Management learned of this deficiency in response to a request for documentation of a check for debarment in connection with the single audit field work in October 2024. Upon further i nquiry, City staff didn't have documentation of this kind. This task slipped through the cracks because a process was not in place to ensure it was completed.
2. In reference to the City's Uniform Guidance Policies, most recently approved by the City Commission on February 5, 2024, page 43, the City will include a suspension/debarment clause in all written contracts in which the vendor will certify that it is not suspended or debarred. Alternatively, the city may request vendor/contractor sign a certification regarding suspension or debarment. Executed certificates and procurement files will be retained by the City Clerk's office. This language was in the policy but was not implemented.
3. A sample certificate is provided on page 51 of the unform guidance policy. This sample certificate, if completed, would have provided evidence but was not implemented. For future contracts, this certificate will be completed prior to the bid award and documentation that it has been completed will be required for future City contracts that are part of a federal grant award.
4. If for any reason this signed certificate is not available prior to the award bid recommendation, City staff will check the vendor's status on Sam.gov and will document the results in the narrative of the memo. This will be required for all contracts related to federal grants. City staff will be provided instructions about how to check the status as by the State of Michigan in the following link... https://www.michigan.gov/msp/-/media/Proiect/Websites/msp/EM HSD/gra nts2/instructions for checking for excluded debarred contractors revised 72020.pdf?rev=0a928fb6b4b54253b2a627f1eb70dcd8&hash=31DC61AC1AB1E38D5A84952C43D27 F82
5. Going forward, City staff will add a note to the narrative of the agenda memo in BoardDocs to state whether the City has a certificate or found that the vendor was not suspended or debarred and provide documentation to be attached to the memo for all bid award recommendations. For example, we might indicate that the vendor/contractor was checked on Sam.gov and the contractor was not suspended or debarred and then follow up with a signed certificate when the contract is signed. Alternatively, a copy of the certificate, if separate from the contract, can be attached to the requisition in the P0 module.
6. This updated process will be shared with all project managers and grant administrators, along with staff in Finance and Clerks offices, so that we can ensure it is completed with each contract and project managers are supported during the busy construction season.
7. When bid award agenda memos route through Finance, they'll be reviewed to ensure this task has been completed and documentation is provided.
This corrective action is being implemented as of this date and is expected to fully resolve the deficiency. Thank you for this opportunity for improvement.
Sincerely,
Kristin M. Collins
Finance Director/Treasurer