Finding Text
Information on the Federal Program: Assistance Listing Number: 21.027 Department Agency: Department of the Treasury State Department: n/a - Direct Compliance Area: Procurement & Suspension & Debarment (I) Criteria: The County should have written standards of conduct in place to verify any entity(vendor) with which the County spends federal expenditures or conducts business transactions be not debarred, suspended, or otherwise excluded per 2 CFR 200.318(h) and 2 CFR 180. The written standard should address conduct covering conflicts of interest governing the performance of its employees engaged in the selection, award, and administration of contracts (Uniform Guidance Section 200.318(c) and 45 CFR sections 52.203-13 and 52.203-16). Condition: The County did not have written controls in place to ensure that vendors were not suspended or debarred or included on the list of vendors prior to entering into a contract with the County. Additionally, we found the County?s written conflicts of interest policy to be vague. Cause: County personnel have not obtained sufficient training related to grant administration. Effect or Potential Effect: The County could enter into a contract with a suspended or debarred party or have a conflict of interest that is undetected. Questioned Costs: None. Repeat Finding: No. Recommendation: The County should adopt written policies that satisfy the requirements of Uniform Guidance associated with suspension, debarment, and conflicts of interest. Furthermore, we recommend that County personnel seek out training related to grant administration. Views of Responsible Official: See the following page for the County?s response to this finding.