Finding 529206 (2024-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-20
Audit: 347195
Organization: City of Independence, Missouri (MO)
Auditor: Rubinbrown LLP

AI Summary

  • Core Issue: One vendor was not checked for suspension or debarment before federal funds were allocated, violating compliance regulations.
  • Impacted Requirements: Regulations in 2 CFR Part 180 require evaluation of vendors to ensure they are not debarred or suspended from federal assistance.
  • Recommended Follow-Up: Management should add a suspension and debarment clause in all relevant contracts or implement alternative checks before allocating federal funds.

Finding Text

Finding No. 2024-002 Significant Deficiency: Procurement and Suspension and Debarment - Compliance and Control Finding ALN 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: US Department of Treasury Pass-Through Entity: Not Applicable Criteria or Specific Requirement: The regulations in 2 CFR Part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Audit procedures revealed that for one contract tested, the vendor was not evaluated for suspension or debarment prior to allocating federal funds to the contract. Cause: The vendor did not include a suspension and debarment clause representing that the vendor is not suspended and debarred, and the City did not evaluate the vendor for suspension and debarment prior to allocating federal funds to the contract. Effect: Suspension and debarment provisions were not met for one of four contracts tested. Questioned Costs: Not Applicable. Context: Out of four contracts tested, one contract tested did not include a suspension and debarment clause representing that the vendor is not suspended or debarred and that the vendor was not evaluated for suspension or debarment prior to allocating federal funds to the contract. Identification as a repeat finding: This is a first time finding. Recommendation: We recommend that management include a suspension and debarment clause in all contracts which may get allocated to federal funding prior to allocating federal funds to the contract or perform alternative procedures to ensure vendor is not suspended or debarred. Views of Responsible Officials: See Corrective Action Plan.

Corrective Action Plan

On contracts and purchase orders where the City is utilizing Federal funds – we will add a clause to contracts and require a certification on purchase orders for suspension and debarment. This will require the vendor to certify that they are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1105648 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $485,189
21.027 Coronavirus State and Local Fiscal Recovery Funds $477,601
20.507 Federal Transit Formula Grants $371,640
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $332,061
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $269,259
16.835 Body Worn Camera Policy and Implementation $192,695
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $191,932
32.004 Universal Service Fund - Schools and Libraries $185,328
20.933 National Infrastructure Investments $145,531
93.069 Public Health Emergency Preparedness $121,967
20.600 State and Community Highway Safety $80,330
97.042 Emergency Management Performance Grants $76,819
16.738 Edward Byrne Memorial Justice Assistance Grant Program $59,486
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $54,307
20.205 Highway Planning and Construction $28,752
93.268 Immunization Cooperative Agreements $27,886
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $18,805
95.001 High Intensity Drug Trafficking Areas Program $15,976
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $15,003
10.569 Emergency Food Assistance Program (food Commodities) $13,391
97.067 Homeland Security Grant Program $12,442
93.008 Medical Reserve Corps Small Grant Program $12,160
14.239 Home Investment Partnerships Program $10,155
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $6,400
93.103 Food and Drug Administration Research $6,184
20.616 National Priority Safety Programs $3,937
93.575 Child Care and Development Block Grant $2,212
20.607 Alcohol Open Container Requirements $2,120
10.559 Summer Food Service Program for Children $1,680
93.994 Maternal and Child Health Services Block Grant to the States $1,208
16.922 Equitable Sharing Program $789
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $610
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $305
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $35