Finding Text
Federal agency: U.S. Treasury
Federal program title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; City of Urbana, Illinois
Pass-Through Number(s): 20220245; 02220246; 2224-FF-CO
Award Period: 7/1/2023-12/31/2026; 3/1/2023-12/30/2023; 12/15/2023-12/31/2024; 3/1/2022-12/31/2023; 3/1/2022-12/31/2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: § 200.214 Suspension and debarment indicates nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: The Organization did not perform the search of suspension and debarment, so it did not meet the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate suspension and debarment process.
Questioned costs: N/A
Context: 4 of 4 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract.
Cause: Error by management in understanding Uniform Guidance requirements.
Effect: Lack of appropriate suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical.
Repeat Finding: Repeat Finding of 2023-004.
Recommendation: We recommend the Organization revised its internal controls related to suspension and debarment such that they align with the requirements of the Uniform Guidance.
Views of responsible officials: The Organization has added a Procurement, Suspension and Debarment policy and will continue to verify contractors as required. The Organization will improve on documentation procedures for these verifications.