Finding Text
Assistance Listing, Federal Agency, and Program Name - 20.941, U.S. Department of Transportation, Strengthening Mobility and Revolutionizing Transportation (SMART) Grants Program
Federal Award Identification Number and Year - SMARTFY22N1P1G34-A01
Pass through Entity - Not applicable
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards.
Condition - The Road Commission could not provide evidence that it performed a check to verify contractors were not suspended or debarred.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Not applicable
Context - The Road Commission used the grant to procure services from one contractor, that was paid $1,894,112 with grant funds, and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract with them. Plante Moran reviewed the SAM.gov website noting the vendor was not listed as suspended or disbarred.
Cause and Effect - The Road Commission did not retain evidence to support that it had conducted the search for whether a contractor was suspended or debarred prior to entering into a contract.
Recommendation - We recommend the Road Commission implement controls to ensure documentation is maintained to support that contractors are not suspended or debarred.
Views of Responsible Officials and Corrective Action Plan - The Road Commission will establish formal policies around the internal review of contractors to ensure they are not suspended or debarred. In addition, the policy will ensure formal documentation of this review is maintained in the associated project.