Finding Text
2024-007 – Suspension and Debarment
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Suspension and Debarment).
Federal program(s)
U.S. Department of Treasury -
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) (ALN 21.027); Direct award, and Passed through Michigan State Housing Development Authority and Michigan Department of Natural Resources; All project numbers.
Criteria. Under the requirements of 2 CFR Part 180, for covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity.
Condition. For three of the four vendors selected for testing, the County was unable to provide evidence that the vendors were not suspended, debarred, or otherwise excluded at the time they were engaged to provide goods or services.
Cause. The County does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance.
Effect. As a result of this condition, the County was exposed to an increased risk that disbursements of federal awards could be made to vendors or subrecipients suspended or debarred by the federal government.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the County review its written policies and procedures over federal awards with employees responsible for grant compliance to ensure that they are being followed consistently.
View of Responsible Officials. Vendors are reviewed based on specific criteria upon addition to the accounts payable system for the County. This review process includes review for suspension, debarment, and excluded parties. The County will review grant compliance requirements with employees responsible for federal awards and request retention of documents verifying compliance.
Responsible Official. County Administrator/Controller
Estimated Completion Date. December 31, 2025