Finding 573765 (2024-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-08-18
Audit: 364417
Organization: City of Thornton, Colorado (CO)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The City lacks adequate controls to verify that vendors are not suspended or debarred before entering contracts.
  • Impacted Requirements: Compliance with federal regulations requiring pre-contract verification of vendor eligibility for federal funds.
  • Recommended Follow-Up: Implement procedures to ensure suspension and debarment checks are completed prior to contracting with vendors.

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.

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring

Other Findings in this Audit

  • 573761 2024-003
    Significant Deficiency
  • 573762 2024-002
    Significant Deficiency
  • 573763 2024-002
    Significant Deficiency
  • 573764 2024-002
    Significant Deficiency
  • 573766 2024-003
    Significant Deficiency
  • 1150203 2024-003
    Significant Deficiency
  • 1150204 2024-002
    Significant Deficiency
  • 1150205 2024-002
    Significant Deficiency
  • 1150206 2024-002
    Significant Deficiency
  • 1150207 2024-002
    Significant Deficiency
  • 1150208 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.939 Safe Streets and Roads for All $362,689
21.027 Coronavirus State and Local Fiscal Recovery Funds $357,389
97.044 Assistance to Firefighters Grant $216,120
16.575 Crime Victim Assistance $177,836
81.128 Energy Efficiency and Conservation Block Grant Program (eecbg) $174,930
16.710 Public Safety Partnership and Community Policing Grants $105,555
20.205 Highway Planning and Construction $50,626
16.738 Edward Byrne Memorial Justice Assistance Grant Program $33,403
20.616 National Priority Safety Programs $26,121
14.218 Community Development Block Grants/entitlement Grants $25,588
16.753 Congressionally Recommended Awards $23,257
16.922 Equitable Sharing Program $18,720
20.600 State and Community Highway Safety $14,535
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $1,000
97.067 Homeland Security Grant Program $956
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $-11,980
15.507 Watersmart (sustain and Manage America’s Resources for Tomorrow) $-22,303