Finding Text
Reference Number: 2024-002
Federal Agency: U.S. Department of the Treasury
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (American Rescue Plan Act)
Assistance Listing Number: 21.027
Federal Award Identification Number Not Available
Federal Award Year 2024
Pass-Through Agency: N/A
Pass-Through Number: N/A
Compliance Requirement: Suspension and Debarment
Award Period: 7/1/2023 - 6/30/2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement:
Compliance: 2 CFR 200.213 Suspension and Debarment restricts 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.
2 CFR 180.300 states that an entity may determine suspension and debarment status by:
(a) Checking SAM (System for Award Management) Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work
to individuals and firms or economic considerations.
Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non-Federal entity
is managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should comply with guidance in “Standards for
Internal Control in the Federal Government” issued by the Comptroller General of the United States or
the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).
Condition:
The County could not provide supporting documentation that suspension and debarment status was
determined prior to award.
Context:
The suspension and debarment status for three out of seven vendors was not documented.
Questioned costs:
There are no questioned costs related to this finding as the vendors were not federally suspended or
debarred.
Cause:
The County relied on State policies and procedures for suspension and debarment for State piggyback
contracts, rather than applying their own established controls to these contracts.
Effect:
The County is not in compliance with federal suspension and debarment regulations.
Repeat Finding:
The finding is a repeat of a finding in the immediate prior year. Prior year finding number was 2023-001.
Recommendation:
The County should ensure that established policies and procedures related to suspension and
debarment are applied to all contracts, even for piggyback agreements adopted from the state.
Views of Responsible Officials and Planned Corrective Action:
The County regularly checks Sam.gov for suspension and debarment transactions. We relied on state
policies and procedures regarding the contracts in question as they were piggyback contracts. Moving
forward, we will ensure thorough documentation of our reviews to maintain diligence in this area.