Finding Text
Repeat Finding: No
Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal
Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Treasury
Pass-Through Agency: N/A
Federal Award Number: N/A
Type of Finding: Significant Deficiency
CRITERIA:
2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of
the United States and the “Internal Control Integrated Framework”, issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). Non-Federal entities are
prohibited from contracting with or making sub awards under covered transactions to parties that
are suspended or debarred. “Covered transactions” include those procurement contracts for goods
and services awarded under a non-procurement transaction that are expected to equal or exceed
$25,000 or meet certain other criteria as specified in 2 CFR §180.220.
CONDITION:
Verification of suspension and debarment was not performed for all vendors with whom the Town
spent at least $25,000 using federal grant monies.
QUESTIONED COSTS:
N/A
CONTEXT:
Payments exceeding $25,000 were made to 6 vendors totaling $768,885 for the fiscal year ended
June 30, 2023. Total expenditures for the Coronavirus State and Local Fiscal Recovery Plan were
$789,178 for the fiscal year ended June 30, 2023.
CAUSE:
The internal controls over the suspension and debarment were not adequately designed or
implemented.
EFFECT:
Payments could be made to parties who are suspended or debarred and not be identified by
management.
RECOMMENDATION:
Officials should implement policies and procedures which ensure compliance for parties subject
to the suspension and debarment requirement.
VIEWS OF RESPONSIBLE OFFICIALS:
Management concurs with the finding and has developed a plan to correct the finding. See
corrective action plan.