Finding 597605 (2022-002)

Finding 2022-002 AL No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Agency U.S. Department of Treasury Pass-through Agency Not applicable Award Number / Year Not applicable Department Green County Department of Finance Criteria: The Uniform Guidance require that prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and sub recipients are not suspended, debarred or otherwise excluded pursuant to 31 CFR section 19.300. Condition/Context: During testing, it was noted that the County could not provide evidence this verification had been completed for the two vendors tested. The sample was not statistically valid. Cause: The County did not have evidence verification was completed. Questioned Costs: None noted. Effect: The County could conduct business with a vendor who is suspended or barred. Recommendation: We recommend the County create a procedure that includes one of the following ways to complete this verification. 1. checking the System for Award Management Exclusions maintained by the General Services Administration and available at SAM.gov. Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System, 2. collecting a certification from the entity, or 3. adding a clause or condition to the covered transaction with that entity, 2 CFR section 180.300. Management's Response: The County has established the process of doing the System for Award Management validation and attaching screen shots of the results to each vendor. Contracts are reviewed by Corporation Counsel and they determine if the clause should be added. Regardless, they are still validated by SAM.