Finding 587136 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-01-30
Audit: 14412
Organization: Town of Woodbridge (CT)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The Town failed to document vendor verification against the System for Award Management (SAM) to ensure compliance with federal suspension and debarment requirements.
  • Impacted Requirements: This finding relates to 2 CFR Part 200, which mandates that non-federal entities verify that vendors are not suspended or debarred before engaging in federally-funded contracts.
  • Recommended Follow-Up: The Town should establish a formal policy to document vendor verification procedures to ensure compliance and maintain necessary records.

Finding Text

Finding 2023-001 - Procurement and Suspension, and Debarment - Internal Control over Verification Against the System for Award Management (“SAM”) Assistance Listing Program Title and Number- Coronavirus State and Local Fiscal Recovery Funds 21.027 Federal Agency- Department of Treasury Pass-through Entity- State Office of Policy and Management, State Department of Education Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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. Condition: During our audit, we noted that the Town did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the Town has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the Town makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the Town was followings its policy, the Town could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 13 out of 13 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the Town implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: The Town agrees with the finding and the recommendation.

Categories

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

Other Findings in this Audit

  • 10693 2023-001
    Significant Deficiency
  • 10694 2023-001
    Significant Deficiency
  • 10695 2023-001
    Significant Deficiency
  • 587135 2023-001
    Significant Deficiency
  • 587137 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $100,918
21.027 Coronavirus State and Local Fiscal Recovery Funds $63,162
10.560 State Administrative Expenses for Child Nutrition $30,255
84.010 Title I Grants to Local Educational Agencies $15,296
84.367 Improving Teacher Quality State Grants $12,555
10.555 National School Lunch Program $10,967
84.027 Special Education_grants to States $10,400
84.424 Student Support and Academic Enrichment Program $8,091
20.616 National Priority Safety Programs $6,240
90.401 Help America Vote Act Requirements Payments $4,226
10.649 Pandemic Ebt Administrative Costs $628
84.173 Special Education_preschool Grants $444
20.600 State and Community Highway Safety $436