Finding 571937 (2024-002)

ARPA – Suspension & Debarment Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: March 3, 2021 – December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Requirement: Procurement, Suspension & 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: The City entered into a procurement transaction that exceeded the covered threshold and did not perform a search for suspension and debarment prior to approving the procurement transaction in accordance with 2 CFR section 180.220. The City subsequently performed a search and the vendor was not suspended or disbarred. Questioned Costs: None Context: The City did not perform a search for the two procurement transactions that exceeded the covered transaction threshold. Cause: The City did not have procedures implemented to ensure that the vendor was not suspended or debarred prior to entering into a procurement transaction. Instead the City was performing annual checks every fall. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: No Recommendation: We recommend the City revise its policies and procedures to ensure that documentation related to suspension and debarment be presented with the procurement action prior to approval. Views of Responsible Officials: Refer to the management response per the corrective action plan.