Finding 2024-003: TCFB was negligent in two areas for one of their purchases: No record of vendor verification that they were not suspended or disbarred and no WSDA prior approval for the purchase which was over $5,000. This was in violation of both their internal procedures and WSDA requirements.
The Problem:
During testing the auditors noted that one instance of purchasing using WSDA funds was made without WSDA prior approval and proper documentation of suspension and debarment or WSDA prior approval.
Established Standard:
Organization must verify SAM registration and conduct suspension, and debarment checks prior to entering into any sub-agency agreement, contract, purchase, or equipment repair over $5,000. It is recommended that lead agency verifies, at least annually, that sub agencies and vendors are not suspended or debarred. Information about suspension and debarment checks is to be entered onto a spreadsheet of approved vendors.
When the lead agency enters into a covered transaction with another agency or vendor, lead agency must verify that the entity with whom business is transacted is registered with SAM and is not excluded or disqualified. There are two methods for verification:
A. Checking SAM.GOV exclusions (this method requires saving a copy of the verification search)
B. Collecting a signed certification from the vendor.
Actions to be taken:
• Updated training of TCFB staff on the Policy/Procedures for procurements using WSDA funding.
• Create step-by-step instructions for purchases using WSDA funding.
• Effective October 1, 2024 WSDA’s threshold for preapprovals changed to $10,000. We will update our purchasing policy to reflect this change.
Action Assignments:
• Instruction checklist will be created by lead purchaser. • Lead purchaser will ensure that any purchases follow the Policy/Procedures for procurement.
• Lead purchaser will be responsible for documenting SAM registration, Suspension and Debarment check, and WSDA pre-approvals. The documentation will consist of a copy of the exclusions page on SAM.GOV, as well as a spreadsheet of approved vendors with a date of last check.
Timeline:
• Instruction checklist for purchases using WSDA funds will be created by July 1st, 2025.
• A spreadsheet has already been created to capture the information concerning Suspension and Debarment checks. A separate folder contains copies of each entities exclusion page from SAM.GOV.
Verify Implementation:
• In July 2025 Lead Purchaser will submit to the Executive Director:
A. A copy of step-by-step instruction checklist.
B. A copy of the spreadsheet with Suspension and Debarment checks
C. Copies of exclusion pages from SAM.GOV
Finance Dept. will verify invoice have received WSDA prior Approvals