Finding Text
2024-002 Significant Deficiency in Internal Controls over Compliance and
Compliance – Procurement – Suspension and Debarment
Agency: U.S. Department of the Treasury
Program(s) and
Federal Award
Listing Number(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN: 21.027
FAIN: None
New or Repeat: New Criteria: The regulations in 2 CFR part 180 restrict making subawards and
contracts with certain parties that are debarred, suspended, or otherwise
excluded from receiving or participating in Federal awards. Management
is responsible for ensuring it has designed and implemented internal
controls over compliance for this requirement as it applies to its federally
funded programs.
Condition: Upon request the City was unable to provide documentation to support
whether the required suspended/debarred certification was completed
within a timely manner or was received from the vendor when the
contract was signed. Although the City, upon our request, checked and
found there to be no issues, there was no documentation to indicate a
suspended/disbarred verification check was completed prior to entering
the contract with the sole vendor used for this program.
Cause: Inconsistent implementation of documentation retention controls and
staff turnover contributed to the inability to retrieve or verify the required
suspended/debarred verification was completed in a timely manner for
the contract.
Context: Only one vendor was paid by contract and subject to the
suspended/debarred procurement requirement in this program.
Effect: Lack of consistent implementation of documentation retention controls is
considered a control weakness and is reportable as a significant
deficiency. As the required verification was completed, although not
timely, the noncompliance is considered not material to the program and
therefore is reported as an other matter.
Recommendation: Management should ensure controls over retaining documentation of
compliance with procurement requirements are followed consistently.
This should include maintaining evidence of required approvals or
reviews and assigning responsibility for recordkeeping, especially during
periods of staff transition.
View of responsible
officials: Management concurs with this finding, see corrective action plan.