Finding 518242 (2024-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-01-08
Audit: 336577
Organization: City of Ann Arbor, Michigan (MI)

AI Summary

  • Core Issue: The City failed to verify that two out of three vendors awarded contracts were not suspended or debarred, which is a requirement for contracts over $25,000.
  • Impacted Requirements: Compliance with 2 CFR Part 180 is necessary to ensure federal funds are not disbursed to ineligible vendors.
  • Recommended Follow-Up: The City should enhance its policies to ensure proper documentation of vendor verifications is maintained for all federal contracts exceeding $25,000.

Finding Text

2024-002 – Suspension and Debarment – Verification. Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Treasury - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027). Criteria. Under the requirements of 2 CFR Part 180 procurement contracts for goods and services that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor, or including a clause or condition to the covered transaction with that entity. Condition. The City did not provide evidence that two out of three vendors being awarded procurements are not suspended, debarred, or otherwise excluded when the City hired the vendors to provide goods or services. Cause. The City does not have the proper internal controls in place to ensure that evidence of verification of procured transaction is performed in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause funds to be disbursed to contractors or vendors who are not eligible to have goods or services purchased with federal monies. Questioned Costs. No costs have been questioned as a result of this finding. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded procurements were excluded parties. Recommendation. We recommend that the City review its written policies and procedures over federal awards and enforce to ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services in excess of $25,000. View of Responsible Officials. Management concurs with the finding. The City has recently hired a Finance Specialist who will be responsible for federal award compliance, including suspension and debarment verifications. This person will be tasked with retaining documentation for all vendors awarded federal funding in excess of $25,000. Responsible Official. Marti Praschan, Chief Financial Officer. Estimated Completion Date. June 30, 2025.

Corrective Action Plan

2024-002 – Suspension and Debarment – Verification. Auditor Description of Condition and Effect. The City did not provide evidence that two out of three vendors being awarded procurements are not suspended, debarred or otherwise excluded when the City hired the vendors to provide goods or services. The failure to monitor suspension and debarment could cause funds to be disbursed to contractors or vendors who are not eligible to have goods or services purchased with federal monies. Auditor Recommendation. We recommend that the City review its written policies and procedures over federal awards and enforce to ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services in excess of$25,000. Responsible Person: Marti Praschan, Chief Financial Officer. Corrective Action. Management concurs with the finding. The City has recently hired a Finance Specialist who will be responsible for federal award compliance, including suspension and debarment verifications. This person will be tasked with retaining documentation for all vendors awarded federal funding in excess of $25,000. Anticipated Completion Date: June 30, 2025.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1094684 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $8.13M
81.087 Renewable Energy Research and Development $255,184
94.006 Americorps $125,267
14.251 Economic Development Initiative, Community Project $106,534
20.106 Airport Improvement Program $59,000
81.041 State Energy Program $56,000
20.205 Highway Planning and Construction $36,833
20.200 Highway Research and Development Program $29,400
16.738 Edward Byrne Memorial Justice Assistance Grant Program $13,630
97.042 Emergency Management Performance Grants $11,332
95.001 High Intensity Drug Trafficking Areas Program $2,792
81.128 Energy Efficiency and Conservation Block Grant Program (eecbg) $2,317
97.039 Hazard Mitigation Grant $1,710
20.939 Safe Streets and Roads for All $1,611