Finding 520618 (2024-003)

B. FINDINGS – MAJOR FEDERAL AWARDS PROGRAM AUDIT Reference Number Significant Deficiency 2024-003 Suspension & Disbarment Program AL 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds U.S. Department of the Treasury Criteria Debarment and suspension regulations in 2 CFR section 180.300 requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by checking SAM.gov, collecting a certification from that entity or adding a clause or condition to the covered transaction with that entity. Condition Dodge County could not provide documentation to support that the County implemented effective controls to ensure that suspension and debarment requirements were followed and adequately documented. We tested vendors pulled from our procurement, suspension, and disbarment sample and reviewed on SAM.gov. We noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal program as of the date of the testing. Cause Lack of procedures and knowledge regarding suspension and debarment requirements. Effect Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation We recommend that management implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. Views of Responsible Officials and Planned Corrective Action: The County will implement procedures to ensure when a contractor is paid with federal funds, https://sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented.