FAC Explorer

Finding 520047 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2025-01-23
Audit: 339555
Organization: Corpus Christi Regional Transportation Authority (TX)
Auditor: Carr Riggs and Ingram LLC

AI Summary

  • Core Issue: The Authority lacks effective internal controls to ensure vendors are regularly checked against the sam.gov website for suspension or debarment.
  • Impacted Requirements: Compliance with 2 CFR 303(a) and 2 CFR 180 Subpart C, which mandate proper vendor review processes for federal awards.
  • Recommended Follow-Up: Implement robust controls to ensure consistent vendor reviews and maintain documentation to verify compliance with suspension and debarment requirements.

Finding Text

2023-001 – Internal controls over compliance – Federal Transit Administration Federal Awards Type of Finding: Significant Deficiency Assistance Listing Number: 20.500; 20.507 Program Name: Federal Transit - Capital Investment Grants (Fixed Guideway Capital Investment Grants); Federal Transit - Formula Funds (Urbanized Area Formula Program) Pass Through Identifying Number: N/A Award Year: 2023 Federal Agency: Federal Transportation Administration FAIN and year: TX04-0114, 2013; TX-18-0074, 2018; TX21-0066, 2021; TX22-0032, 2022; TX-18-0074, 2018; TX21-0038, 2021; TX21-0066, 2021 Criteria: In accordance with 2 CFR.303(a) of the Uniform Guidance, which applies to the Federal Transportation Administration grants, non-Federal entities are required to establish and maintain effective internal controls over federal awards. Specifically, internal controls should be established to ensure the non-federal entity appropriately documents review for suspension and debarment before entering into covered transactions. In addition, 2 CFR 180 Subpart C prohibits participants in Federal awards from entering into covered transactions with suspended or debarred parties. Condition: The Authority did not frequently review the vendors and did not maintain documentation that the vendors were checked against the sam.gov website for suspension or debarment. Cause: The Authority did not frequently review the vendors and did not maintain documentation that the vendors were checked against the sam.gov website for suspension or debarment due to oversight by personnel. Effect: The Authority could potentially enter into transactions with parties that are suspended or debarred. Questioned Costs: N/A Recomendation: It is recommended that the client establish controls in order to ensure that vendors are reviewed and documentation is maintained through sam.gov or similar to verify that they are not suspended or debarred. Views of Responsible Officials: The Procurement department verifies vendors on sam.gov as part of its vendor review process. While there were instances where the Procurement department did notcheck vendors against the sam.gov website for suspension or debarment, these instances were few and far between. The Procurement department is committed to maintaining the highest standards of compliance and is confident that these corrective actions will prevent similar issues. See corrective action plan beginning on page 103.

Corrective Action Plan

Finding: 2023-001 Name of Contact Person: Christina Perez, Director of Procurement Corrective Action: The Procurement department will implement the following corrective actions to address the identified deficiency: • Policy Review and Enhancement: o The Procurement department will reiterate and emphasize the existing requirement in its procurement policy for mandatory checks on all vendors against the sam.gov website for suspension or debarment before entering into any transactions. o The Procurement department will reiterate the procedures for documenting sam.gov checks within its procurement policy, ensuring that staff retains records and can readily retrieve them for audit purposes. • Training and Communication: o The Procurement department will conduct mandatory training for all personnel involved in vendor selection and contract management to reiterate the importance of sam.gov checks and proper documentation as required by its procurement policy. o The Procurement department will develop and disseminate communication materials (e.g. memos, checklists) to reiterate the existing policy and procedures. • Process Improvement: o The Procurement department will implement a secondary review process for vendor documentation to ensure that staff performs all the necessary checks and documents them before any contract is finalized. • Monitoring and Review: o The Procurement department will establish a periodic monitoring process to ensure that staff consistently follows existing policies and procedures regarding vendor checks. Proposed Completion Date: January 8, 2025 Anticipated Completion Date: January 8, 2025

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 520048 2023-001
    Significant Deficiency
  • 520049 2023-001
    Significant Deficiency
  • 520050 2023-001
    Significant Deficiency
  • 520051 2023-001
    Significant Deficiency
  • 520052 2023-001
    Significant Deficiency
  • 520053 2023-001
    Significant Deficiency
  • 1096489 2023-001
    Significant Deficiency
  • 1096490 2023-001
    Significant Deficiency
  • 1096491 2023-001
    Significant Deficiency
  • 1096492 2023-001
    Significant Deficiency
  • 1096493 2023-001
    Significant Deficiency
  • 1096494 2023-001
    Significant Deficiency
  • 1096495 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.507 Federal Transit Formula Grants $6.25M
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $252,926
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $52,128
20.500 Federal Transit Capital Investment Grants $38,542