Finding Text
Information on the federal program:
Federal Agency: Department of Transportation
Pass-Through Entity: Indiana Department of Transportation
Federal Program: Highway Planning and Construction
Assistance Listing Number: 20.205
Compliance Requirement: Procurement – Suspension and Debarment
Audit Findings: Significant Deficiency, Noncompliance
Criteria: 2 CFR 180.300 states: “When you enter into a covered transaction with another person at the next
lower tier, you must verify that the person with whom you intend to do business is not excluded or
disqualified. You do this by:
a) Checking the SAM Exclusions; or
b) Collecting a certification from that person; or
c) Adding a clause or condition to the covered transaction with that person.”
Condition: The City could not provide documentation to support that vendors procured under the Highway
Planning and Construction funding were not suspended or debarred.
Cause: The City had not developed a system of internal controls that would have ensured compliance with
Procurement and Suspension and Debarment compliance requirements for covered transactions.
Effect: The failure to establish internal controls could have enabled noncompliance to go undetected. If
vendors would have been suspended or debarred, the failure to comply with the grant agreement and the
compliance requirement could have resulted in the loss of federal funds to the City.
Questioned costs: There are no questioned costs.
Context: In a sample of two vendors with aggregate disbursements for the year ended December 31,
2022, above the $25,000 covered transaction threshold, Crowe noted the City had not completed a check
for suspension and debarment nor had they obtained a contract clause from the vendor/service provider
certifying that they were not suspended and/or debarred for either sample selection.
Identification as a repeat finding, if applicable: This is not a repeat finding.
Recommendation: We recommend that the City establish and implement control procedures to ensure
compliance with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement. This should include ensuring suspension and debarment checks are performed and
documented prior to entering into the transaction.
Views of responsible officials and planned corrective actions: Management acknowledges the
finding. See management’s corrective action plan attached to this audit report.