Finding 622602 (2022-004)

2022-004 Suspension and Debarment Federal Agency: US Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Number(s): 155811 Award Period: 3/3/2021-12/31/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matter Criteria or Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal 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: The County's Health Department verifies suspension and debarment status when there is a new vendor but did not continue to verify there was no change in that status in subsequent years when the vendor was used again. Questioned Costs: None Context: The one vendor used during 2022 that met the covered transaction threshold did not have any review completed by the County's public health department to ensure they were not suspended or debarred when initiating covered transactions in the current year. Cause: The County's Health Department misunderstood when verification of suspension and debarment status needs to be completed. Effect: County could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: Yes. The prior year finding was Finding 2021-004. Recommendation: We recommend the County use sam.gov or the ELPS listing to review clients prior to entering into procurement transactions in excess of the covered transaction threshold in accordance with the Uniform Guidance. We also recommend that there is a review of this documentation prior to approval of use of the vendor and that documentation of the search and approval is maintained. View of Responsible Officials: There is no disagreement with the audit finding.