Finding Text
NONCOMPLIANCE WITH GRANT TERMS AND CONDITIONS; AIRPORT IMPROVEMENT PROGRAM; AL No. 20.106, GRANT No’s 3-30-0029-019-2023, 3-30-0029-020-2023 and 3-30-0029-017-2022, YEAR ENDED JUNE 30, 2024
Criteria: Per section 19(b) of the grant contracts, the county must require prime contractors to comply with 2 CFR 180.330 when entering into lower-tier transactions with their contractors and sub-contractors.
Condition: 1. The county did not monitor the prime contractor’s compliance with section 19(b) of the grant contract.
Criteria: Special Conditions Section 29 of the grant contracts requires the county to abide by Buy American Executive Orders.
Condition 2: The county did not have supporting documentation as to the source and origin of steel and manufactured products used on the grant funded projects.
Cause: The county does not have a system in place that will allow full compliance with all grant terms and conditions.
Effect: Non-compliance with grant terms and conditions.
Questioned Costs: None
Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward. The county should obtain the required certifications in order to verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Additionally, the county should request and retain supporting documentation as to the source and origin of steel and manufactured products as required by the Buy American Executive Orders.
Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.