FAC Explorer

Finding 547933 (2024-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 351867
Organization: Clackamas County, Oregon (OR)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The County failed to verify vendor status against the sam.gov database for contracts over $25,000, risking compliance violations.
  • Impacted Requirements: Federal regulations mandate checks for suspended or debarred vendors prior to contract execution.
  • Recommended Follow-Up: Implement a process to verify vendor status against sam.gov and ensure documentation of this verification before contract signing.

Finding Text

FINDING 2024-002 – Procurement, Suspension and Debarment – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Federal regulations require that grantees have controls in place to verify that vendors are not suspended or debarred prior to entering into contracts for goods and services exceeding $25,000. Condition: For two of the contracts tested, there was no evidence of verification from sam.gov being obtained to verify vendors were not suspended or debarred prior to conducting business. There was also no evidence in the County’s contract with the vendor that the appropriate language had been included. Context: Of the 39 vendors that had expenditures greater than $25,000, we selected four vendors for procurement testing. Effect: The County could be transacting with parties that are suspended or debarred and may be subject to questioned costs or other sanctions from funding agencies. However, during the course of the audit we verified these vendors were not previously suspended or debarred. Cause: There were ineffective controls in place during the period, along with lack of management oversight. Repeat finding: No Recommendation: We recommend that before the County executes contracts with vendors that exceed $25,000, the vendor is compared to the listing of suspended and debarred vendors on the sam.gov website and that this verification is properly documented. Views of responsible officials: Management agrees with the auditor recommendation.

Corrective Action Plan

Finding 2024-002: Procurement, Suspension and Debarment – Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance Management agrees with the finding and the auditor’s recommendation. Contact Person responsible for corrective action: Elizabeth Comfort Finance Director ecomfort@clackamas.us 503-936-5345 Corrective Action Planned: Procedures will be incorporated into the County workflow to provide additional monitoring, oversight, and record retention related to reporting. These will include: • Timely verification from SAM.gov to verify non-suspension or disbarment status • Procurement to download the timestamped report from SAM.gov • Retain documentation of verification from SAM.gov • Procurement to include appropriate language on all Federal funded awards Anticipated Completion Date: Implemented as a control by the Finance Procurement Division each award March 19, 2025.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 547928 2024-001
    Significant Deficiency
  • 547929 2024-001
    Significant Deficiency
  • 547930 2024-001
    Significant Deficiency
  • 547931 2024-001
    Significant Deficiency
  • 547932 2024-001
    Significant Deficiency
  • 547934 2024-002
    Significant Deficiency
  • 547935 2024-003
    Significant Deficiency
  • 547936 2024-003
    Significant Deficiency
  • 1124370 2024-001
    Significant Deficiency
  • 1124371 2024-001
    Significant Deficiency
  • 1124372 2024-001
    Significant Deficiency
  • 1124373 2024-001
    Significant Deficiency
  • 1124374 2024-001
    Significant Deficiency
  • 1124375 2024-002
    Significant Deficiency
  • 1124376 2024-002
    Significant Deficiency
  • 1124377 2024-003
    Significant Deficiency
  • 1124378 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $19.25M
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $12.53M
93.568 Low-Income Home Energy Assistance $3.48M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $1.44M
93.563 Child Support Services $1.38M
14.267 Continuum of Care Program $1.37M
14.218 Community Development Block Grants/entitlement Grants $1.13M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $883,664
16.922 Equitable Sharing Program $741,372
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $572,458
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $553,557
14.256 Neighborhood Stabilization Program (recovery Act Funded) $428,223
16.575 Crime Victim Assistance $378,180
93.052 National Family Caregiver Support, Title Iii, Part E $372,173
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $368,505
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $351,376
93.069 Public Health Emergency Preparedness $304,174
81.042 Weatherization Assistance for Low-Income Persons $260,966
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $250,000
93.958 Block Grants for Community Mental Health Services $243,180
93.569 Community Services Block Grant $241,667
97.012 Boating Safety Financial Assistance $224,871
81.128 Energy Efficiency and Conservation Block Grant Program (eecbg) $222,781
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $211,253
20.509 Formula Grants for Rural Areas and Tribal Transit Program $209,474
17.805 Homeless Veterans’ Reintegration Program $200,112
93.053 Nutrition Services Incentive Program $187,146
21.016 Equitable Sharing $175,324
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $171,699
93.268 Immunization Cooperative Agreements $171,595
16.812 Second Chance Act Reentry Initiative $170,880
93.499 Low Income Household Water Assistance Program $161,946
93.558 Temporary Assistance for Needy Families $158,084
97.042 Emergency Management Performance Grants $140,287
93.136 Injury Prevention and Control Research and State and Community Based Programs $125,833
93.526 Grants for Capital Development in Health Centers $123,786
93.994 Maternal and Child Health Services Block Grant to the States $122,446
94.016 Americorps Seniors Senior Companion Program (scp) 94.016 $120,861
21.023 Emergency Rental Assistance Program $89,092
93.940 Hiv Prevention Activities Health Department Based $87,470
93.556 Marylee Allen Promoting Safe and Stable Families Program $76,247
93.959 Block Grants for Prevention and Treatment of Substance Abuse $71,687
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $68,000
16.585 Treatment Court Discretionary Grant Program $67,421
16.738 Edward Byrne Memorial Justice Assistance Grant Program $62,435
14.231 Emergency Solutions Grant Program $61,946
66.468 Drinking Water State Revolving Fund $60,416
66.432 State Public Water System Supervision $60,416
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $60,075
20.205 Highway Planning and Construction $54,112
93.217 Family Planning Services $51,391
10.447 Rural Multi-Family Housing Revitalization Demonstration Program (mpr) $50,000
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $46,637
17.259 Wioa Youth Activities $43,000
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $41,200
21.032 Local Assistance and Tribal Consistency Fund $40,000
21.027 Coronavirus State and Local Fiscal Recovery Funds $34,768
94.017 Americorps Seniors Senior Demonstration Program (fgp) 94.017 $32,247
93.778 Medical Assistance Program $25,168
93.527 Grants for New and Expanded Services Under the Health Center Program $22,521
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $22,431
93.324 State Health Insurance Assistance Program $19,500
81.U01 Low-Income Energy Efficiency Program (liee) $19,185
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $18,500
20.600 State and Community Highway Safety $14,116
97.067 Homeland Security Grant Program $13,188
15.234 Secure Rural Schools and Community Self-Determination $13,027
93.071 Medicare Enrollment Assistance Program $8,475
20.507 Federal Transit Formula Grants $6,984
10.664 Cooperative Forestry Assistance $6,947
93.658 Foster Care Title IV-E $5,333
20.616 National Priority Safety Programs $5,259
90.400 Help America Vote College Program $3,141
16.710 Public Safety Partnership and Community Policing Grants $2,455
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $1,588
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $1,518
20.218 Motor Carrier Safety Assistance $1,424
15.622 Sportfishing and Boating Safety Act $1,119
20.939 Safe Streets and Roads for All $521
97.039 Hazard Mitigation Grant $-4,888