Finding 540714 (2024-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-30
Audit: 350401
Organization: South Coast Water District (CA)

AI Summary

  • Core Issue: The District lacks documented evidence of verifying vendor suspension and debarment for covered transactions, despite having procedures in place.
  • Impacted Requirements: Compliance with 2 CFR Part 200 is essential to avoid contracting with suspended or debarred entities.
  • Recommended Follow-Up: Implement and document verification procedures for all vendors, using resources like sam.gov, certifications, or contractual clauses.

Finding Text

Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. The District should have internal controls designed to ensure compliance with these provisions. Condition: The District does currently have procedures in place to verify vendors are not suspended or debarred prior to entering into a transaction with the entity. However, the District was not able to provide evidence that these procedures were performed for the covered transactions related to this grant. Questioned Costs: None. Context: The finding was noted in four of the four transactions tested. However, the transactions were not with entities that are suspended or debarred. Cause: The District had turnover in staff and was not able to locate any evidence that suspension and debarment was verified. Effect: There is a potential the District could contract with a debarred or suspended entity if the verification is not performed. Recommendation: We recommend the District perform suspension and debarment procedures on all vendors with which it plans to enter into a covered transaction and maintain the documentation for evidence of compliance. The District can do this by (a) checking sam.gov exclusions, or (b) collecting a certification from the entity, or (c) adding a clause or condition to the covered transaction with that entity. View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Action taken in response to finding: The District does currently have procedures in place to verify vendors are not suspended or debarred by checking sam.gov. However, additional steps have been taken to require staff to retain the documentation for evidence of compliance when performing vendor suspension and debarment procedures on all vendors with which South Coast Water District (SCWD) plans to enter into a covered transaction. The District has also updated the procurement procedures to ensure staff retain documentation for evidence when performing suspension and debarment procedures on all new and existing vendors by checking sam.gov exclusions or collecting a certificate from the entity. Name(s) of the contact person(s) responsible for corrective action: Jenny Pan Planned completion date for corrective action plan: March 24, 2025.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1117156 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
15.514 Reclamation States Emergency Drought Relief $1.80M
15.504 Water Recycling and Desalination Construction Programs $967,190
15.507 Watersmart (sustain and Manage America’s Resources for Tomorrow) $10,015