Finding 516118 (2024-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2024-12-19
Audit: 333939
Organization: City of Dearborn, Michigan (MI)

AI Summary

  • Core Issue: The City failed to verify that contractors were not suspended or debarred before awarding contracts using federal grant funds.
  • Impacted Requirements: This violates 2 CFR 200.214 and 2 CFR part 180, which mandate checks against debarred parties for federal awards.
  • Recommended Follow-up: Strengthen documentation controls and provide training to staff on compliance with federal procurement regulations.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - 97.044, U.S. Department of Homeland Security, Assistance to Firefighters Grant Federal Award Identification Number and Year - Not available Pass through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition - The City could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The City used the grant to procure goods and services from 13 different contractors and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract with them. Cause and Effect - The City did not retain evidence to support that it had conducted the search for whether a contractor was suspended or debarred prior to entering into a contract. Subsequently, the City did complete the search on Sam.gov and retained evidence to support that the contractor was not suspended of debarred, thereby creating no questioned costs. Recommendation - We recommend the City strengthen its controls to ensure documentation is maintained to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - This item relates to turnover and transition within the purchasing division of the City during the last two years for all of the staff finalizing procurement matters that were replaced due to resignations and retirements. Upon notification of the deficiency, a root cause investigation on the actions involved during the grant procurement were performed to identify cause. The outcome of this investigation will be communicated as educational training within the finance department, which includes purchasing division, operating departmental procurement requestors using federal grant awards, and all accountants. Additionally, management has amended the standard policy for the City to ensure all federal monies are used in accordance with 2 CFR requirements.

Corrective Action Plan

Finding Number: 2024-001 Condition: The City could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Planned Corrective Action: Upon notification of the deficiency, a root cause investigation on the actions involved during the Grant procurement were performed to identify cause. The outcome of this investigation will be communicated as educational training within the Finance Department, which includes Purchasing Division, Operating Departmental procurement requestors using federal grant awards and all Accountants. Additionally, management has amended the standard policy for the City to ensure all federal monies are used in accordance with 2 CFR requirements. Contact person responsible for corrective action: Michael Kennedy, Finance Director Corey Jarocki, Deputy Finance Director Anticipated completion date: 11/19/2024

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 516119 2024-001
    Material Weakness
  • 516120 2024-001
    Material Weakness
  • 516121 2024-001
    Material Weakness
  • 516122 2024-001
    Material Weakness
  • 1092560 2024-001
    Material Weakness
  • 1092561 2024-001
    Material Weakness
  • 1092562 2024-001
    Material Weakness
  • 1092563 2024-001
    Material Weakness
  • 1092564 2024-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
97.083 Staffing for Adequate Fire and Emergency Response (safer) $1.01M
97.044 Assistance to Firefighters Grant $609,549
16.922 Equitable Sharing Program $479,301
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $151,106
14.218 Community Development Block Grants/entitlement Grants $149,757
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $132,836
20.325 Consolidated Rail Infrastructure and Safety Improvements $98,037
16.585 Treatment Court Discretionary Grant Program $91,475
10.569 Emergency Food Assistance Program (food Commodities) $65,085
97.042 Emergency Management Performance Grants $64,166
97.067 Homeland Security Grant Program $41,567
20.205 Highway Planning and Construction $32,740
14.218 Covid-19 - Community Development Block Grants/entitlement Grants $30,019
20.616 National Priority Safety Programs $22,721
97.039 Hazard Mitigation Grant $16,771
20.600 State and Community Highway Safety $14,670
16.738 Edward Byrne Memorial Justice Assistance Grant Program $11,434
16.710 Public Safety Partnership and Community Policing Grants $8,900
45.310 Grants to States $8,308
45.312 National Leadership Grants $7,521
16.607 Bulletproof Vest Partnership Program $825