Finding Text
Finding 2024-002: Suspension and Debarment
Assistance Listing Program Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Program Number: 21.027
Federal Agency: U.S. Department of the Treasury
Award Year: 2024
Criteria: The Federal Government requires that 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 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. In addition, per the Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The City does not have adequate controls in place to ensure that suspension and debarment compliance requirements are met.
Cause: Although the City does have a process in place for verifying vendors paid with federal funds are not suspended or debarred from receiving federal funds, this verification took place after a contract was entered into with the vendor instead of before.
Effect or Potential Effect: In the absence of appropriate controls, the City could enter into a contract with a vendor or subrecipient that is suspended or debarred from participating in federal programs, which would result in noncompliance with federal program requirements.
Questioned Costs: None.
Context: Out of a sample of four vendors where suspension and debarment checks were completed by the City, this verification was not completed prior to the City entering into contracts with those vendors.
Identification as a Repeat Finding, If Applicable: Not Applicable
Recommendation: We recommend the City implement procedures to properly ensure that suspension and debarment verification occurs prior entering into a covered transaction with a vendor that receives federal funds.
View of Responsible Officials: Management agrees with this finding.