Finding Text
2024-002 - Procurement, Suspension and Debarment. Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance. Federal Program(s) U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027). Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the government. Such procedures are required whenever the amount disbursed to a single vendor in a given fiscal year is expected to be at least $25,000. Also, recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. In cases where the vendor did not sign a suspension or debarment certification, either within the vendor contract or as a separate certification, the City did not have a process in place to manually search the Excluded Parties List System to verify the vendor was not suspended or debarred. Cause. This condition is the result of lack of management oversight. Effect. As a result of this condition, while none of the vendors tested appeared to be suspended or debarred, documentation does not exist to support that the City verified its vendors paid with federal dollars were not suspended or debarred prior to contracting with them. Questioned Costs. No costs were questioned as a result of this finding. Recommendation. We recommend that the City create procedures and a related checklist to ensure all federal requirements are being addressed. View of Responsible Official. Due to the influx of new employees managing federal funds under the Coronavirus State and Local Fiscal Recovery Funds program, many were unaware of the requirement to document their searches for suspended or debarred vendors. As a result, search results showing no matches were not retained in the files. Moving forward, all relevant employees will receive additional training to ensure proper documentation of these searches. This training will help to ensure this requirement is consistently met in the future. Responsible Official. Finance Director. Estimated Completion Date. June 30, 2025.