Finding Text
Information on the federal program:
Federal Agency: Department of the Treasury
Pass-Through Entity: N/A – Direct Grant
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Assistance Listing Number: 21.027
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 CSLFRF
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 six vendors with aggregate disbursements for the year ended December 31, 2022,
above the $25,000 covered transaction threshold, Crowe noted four vendors that 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.
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.