Finding 546974 (2024-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: One vendor was not verified for debarment or suspension, violating compliance requirements.
  • Impacted Requirements: Nonfederal entities must ensure vendors are not excluded from Federal assistance programs as per 2 CFR Part 200.214.
  • Recommended Follow-Up: Strengthen procedures to document vendor verification before transactions to prevent future compliance issues.

Finding Text

2024-001 COVID-19 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 Federal Award Identification Number: Not Available. Award Period: March 3, 2021 through December 31, 2024 Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The United States Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations 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 and Context: For one vendor in our audit sample of eight, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities for the fiscal year ended June 30, 2024. Questioned Costs: None. The vendor was not suspended or debarred. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities prior to entering into a transaction. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Action taken in response to finding: The Comptroller’s Office has reiterated procedures to departments to ensure they document the verifications with either contract certifications and/or screenshots of SAM.gov searches. Name(s) of the contact person(s) responsible for corrective action: Stephen Curley, Comptroller. Planned completion date for corrective action plan: Completed. An email was sent out to all department heads to distribute and reaffirm with staff that they need to ensure all vendors paid from federal funding are not suspended or debarred from receiving federal funds which included procedures on how to confirm this.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 546975 2024-002
    Material Weakness
  • 546976 2024-003
    Significant Deficiency
  • 546977 2024-004
    Significant Deficiency
  • 546978 2024-005
    Significant Deficiency
  • 1123416 2024-001
    Significant Deficiency
  • 1123417 2024-002
    Material Weakness
  • 1123418 2024-003
    Significant Deficiency
  • 1123419 2024-004
    Significant Deficiency
  • 1123420 2024-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $11.30M
14.239 Home Investment Partnerships Program $1.51M
93.778 Medical Assistance Program $794,084
84.425 Education Stabilization Fund $531,950
84.010 Title I Grants to Local Educational Agencies $464,965
84.027 Special Education Grants to States $341,179
10.555 National School Lunch Program $328,529
97.044 Assistance to Firefighters Grant $264,047
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $185,560
10.553 School Breakfast Program $183,355
14.231 Emergency Solutions Grant Program $140,764
84.048 Career and Technical Education -- Basic Grants to States $135,767
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $120,733
84.365 English Language Acquisition State Grants $98,615
16.580 Edward Byrne Memorial State and Local Law Enforcement Assistance Discretionary Grants Program $50,000
84.424 Student Support and Academic Enrichment Program $46,977
84.173 Sped Early Childhood Allocation $39,425
16.U00 Dea Asset Forefeitures $36,398
16.U00 Dea Support Overtime Reimbursements $33,812
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $25,273
16.607 Bulletproof Vest Partnership Program $17,362
93.103 Food and Drug Administration Research $13,658
10.579 Child Nutrition Discretionary Grants Limited Availability $12,159
84.U00 Influence 100 Grant $2,000
84.027A Reducing Time-Out Rooms $540
14.218 Community Development Block Grants/entitlement Grants $257