Finding Text
2024-006 (2023-009) – SUSPENSION AND DEBARMENT
Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards and (G) Instance of Non-compliance related to Federal Awards
Funding Agency: U.S. Department of Transportation
Title: Airport Improvement Program
AL #: 20.106
Award #: 3-35-0039-031-2024, 3-35-0039-027-2022, 3-35-0039-028-2022, 3-35-0039-029-2023
Award Period: May 1, 2024 – January 1, 2025, December 13, 2021 – December 13, 2025, June 24, 2022 – June 24, 2026, July 3, 2023 – July 7, 2027
Questioned Costs: None
Funding Agency: U.S. Department of the Treasury
Title: COVID 19 - Coronavirus State and Local Fiscal Recovery Fund
AL #: 21.027
Award #: 23-ZH5053-23
Award Period: March 3, 2021 – December 31, 2024
Questioned Costs: None
Statement of Condition
The County does not adequately document its review process to confirm vendor suspension and debarment status prior to entering into federally funded transactions.
Management’s Progress Toward Prior Year Corrective Action Plan: There remains no documented evidence of vendor suspension and debarment checks prior to covered transactions.
Criteria
Per 2 CFR 180.300, entering into a covered transaction you must verify that the business is not excluded or disqualified by checking SAM exclusions, or collecting a certification form, or adding a clause or condition to the covered transaction.
Cause
The County has not developed or implemented procedures to address the federal program suspension and debarment documentation requirements under the Uniform Guidance.
Effect
Failing to adequately verify suspension and debarment could result in the County engaging federally funded vendors who are prohibited from participating in federal programs, potentially causing disallowed costs, repayment obligations, or the loss of future federal funding.
Recommendation
We recommend the County:
• Update procurement policies promptly to fully comply with all applicable federal procurement guidelines.
• Establish and implement documented processes for verifying and recording suspension and debarment checks before engaging in covered transactions.
• Provide ongoing training for procurement staff to ensure proper understanding and consistent application of federal procurement standards, specifically regarding suspension/debarment checks.