Finding Text
Assistance Listing, Federal Agency, and Program Name - 20.507, Department of Transportation, Federal Transit Cluster
Federal Award Identification Number and Year - MI-2022-032, MI-2022-048, MI-2020-061 and MI-2018-018
Pass through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.214 non federal 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 180.300 specify that when you enter into a covered transaction you must verify that whom you intend to do business with is not excluded or disqualified.
Condition - The Authority could not provide evidence that it performed a check to verify all subrecipients were not suspended or debarred.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Not applicable
Context - The Authority had 16 subrecipient communities during fiscal year 2024 and could not provide evidence that the check for suspension and debarment was completed prior to entering a subrecipient ageements with two of the communities selected for testing.
Cause and Effect - The Authority did not retain evidence to support that they had conducted the search for whether a subrecipient was suspended or debarred prior to entering into a contract. Subsequently, we performed a search of sam.gov to verify that the subrecipients were not suspended or debarred, noting they were not.
Recommendation - We recommend the Authority strengthen its controls to ensure documentation is maintained to support that subrecipients are not suspended or debarred.
Views of Responsible Officials and Corrective Action Plan - SMART is in agreement with this finding. SMART has reviewed and corrected procedures around our suspension and debarment reviews to include all subrecipient award programs. The Manager of Capital Grant Programs will review all subrecipients in new grant awards, and work with the Manager of Transit Asset Management to ensure we have documented our review of subrecipient suspension and debarment.