The following corrective actions have either been implemented or will be implemented to prevent recurrence:
1. Audit Documentation: For the identified contract, C/CAG obtained and affidavit from the vendor affirming their compliance with suspension and debarment requirements at the time of contract. C/CAG also confirmed that the consultant is currently not on the suspension and debarment list. This
documentation has been shared with the auditors and added to the project file.
2. Quality Assurance: Staff confirmed that the C/CAG’s other federally funded contracts included the required suspension and debarment requirements.
3. Staff Training: All staff members that work or might work on federally funded activities have completed training on federal procurement requirements, including guidance on suspension and debarment protocols. This training references the necessity of conducting SAM.gov checks and
obtaining certifications for all federalized contracts. The specific training was: "Navigating the Uniform Guidance: Procurement Standards," and it was conducted on December 18, 2024. The provider of the training was “Federal Grants Training.” Ten C/CAG staff attended the training, including staff in the following positions: Executive Director, Deputy Director, Stormwater Program
Director, Transportation Systems Coordinator, Senior Program Specialist, and Program Specialist. Copied of the completion certificates are available upon request. To ensure ongoing compliance, all future staff working on federally funded activities will also complete training on relevant federal requirements as part of their onboarding or ongoing professional development.
4. Contract Template and Procurement Policy Update: C/CAG is in the process of updating its standard contract template and the Procurement Policy to include suspension and debarment language for all contracts, regardless of funding source. This proactive measure ensures compliance across all contracts, even if funding transitions from non-federal to federal sources. Starting in February 2025, all relevant new contracts will have suspension and debarment language. The new contract template is expected to take effect beginning in April of 2025, and all contracts signed from that time onward will use the updated template. Furthermore, C/CAG will continue to review and update its contracts and policies regularly to ensure compliance with evolving regulations and standards.
5. Verification Procedures: Moving forward, C/CAG will:
o Require vendors to provide a certification of compliance with suspension and debarment requirements before executing any agreement.
o Conduct SAM.gov checks for all federally funded contracts.