Finding Text
Federal Program
21.027 – Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Criteria
Non-federal entities are prohibited from contracting with or making subawards under covered
transactions to parties that are suspended or debarred. “Covered transactions” include contracts
for goods and services awarded under a non-procurement transaction (e.g., grant or
cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other
criteria as specified in 2 CFR section 180.220.
Condition
We noted during testing that the only 2 vendors who qualified for suspension and debarment
testing, were not checked for suspension or debarment.
Cause
Management oversight.
Questioned Costs
None
Context
The District did not ensure they were entering into covered transactions with vendors who do
not have an active exclusion from federal status.
Effect
The District was not in compliance with Uniform Guidance and had an increased risk of entering
into a covered transaction with a vendor who has an active exclusion of federal funds.
Repeat Finding
No
Recommendation
The District should document all covered vendors used to ensure suspension and debarment
requirements are met.
Views of Responsible Officials
The District will ensure all covered vendors meet the requirements of suspension and
debarment.