Finding Text
Reference Number: 2023-001
Prior Year Finding: Yes
Federal Agency: U.S. Department of the Treasury & U.S. Environmental Protection
Agency
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (American
Rescue Plan Act) & Clean Water State Revolving Funds
Assistance Listing Number: 21.027 & 66.458
Compliance Requirement: Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement:
Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts
with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for
participation in Federal assistance programs or activities.
2 CFR 180.300 states that an entity may determine suspension and debarment status by:
(a) Checking SAM (System for Award Management) Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work
to individuals and firms or economic considerations.
Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: 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 comply with guidance in “Standards for
Internal Control in the Federal Government” issued by the Comptroller General of the United States or
the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).
Condition:
The County could not provide supporting documentation that suspension and debarment status was
determined prior to award.
Context:
The suspension and debarment status for three out of eight vendors was not documented related to the
Coronavirus State and Local Fiscal Recovery Funds program. The suspension and debarment status
for four out of five vendors was not documented related to the Clean Water State Revolving Funds
program.
Questioned costs:
There are no questioned costs related to this finding as the vendors were not federally suspended or
debarred.
Cause:
The County did not establish effective internal controls over suspension and debarment transactions.
Effect:
The County is not in compliance with federal suspension and debarment regulations.
Recommendation:
The County should ensure they maintain audit documentation to support their review of suspension and
debarment status.
Views of responsible officials:
The County does check Sam.gov for suspension and debarment transactions. Documentation was
retained, but was lost due to a network intrusion. We will remain diligent in documenting our reviews.