Finding 571759 (2024-002)

Federal Agency: U.S. Department of the Treasury Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2024 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: January 1, 2024, through December 31, 2024. Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: The City should ensure Suspension & Debarment procedures are documented, followed and performed. Condition: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Questioned costs: None noted. Context: The City was unaware consultants also needed to be checked for suspension and debarment. Cause: Procedures not formalized when updated and one vendor was not properly verified. Effect: Lack of updated policies and suspension & debarment procedures being performed could lead to the vendor entering into a covered transaction with a suspended or debarred procedure or that incorrect procedures being performed. Repeat Finding: No. Recommendation: We recommend the City formalizes their suspension & debarment procedures in a policy and ensure they check suspension & debarment for all vendors prior to entering into a covered transaction. Views of responsible officials: There is no disagreement with the audit finding.