Finding Text
Finding 2022-002 ? Suspension and Debarment Major Program: COVID-19: American Rescue Plan Act of 2021 - Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Federal Agency: Department of the Treasury Pass-Through: County of Cook, Illinois Grantor Number: 831926584 Award Period: July 29, 2021 through November 30, 2024 Type of Finding: Significant deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g. grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition: Through audit procedures performed, we noted that the Foundation does not have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Questioned Costs: None. Context: During our testing, we noted a formal policy was not in place over suspension and debarment. We also noted that the Foundation did not determine or verify whether one vendor in which a contract was entered into was not suspended or debarred prior to entering into the contract. Cause: Policies and procedures had not been put into place to verify whether the Foundation is entering into covered transactions with entities that are not suspended or debarred. Effect: Possible receipt of federal funds or assistance by an ineligible contractor. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that current policies and procedures over covered transactions be updated to include one of the following procedures related to suspension and debarment: ? Searching for the person or entity within the Excluded Parties List System; ? Collecting certification from the person or entity; or ? Adding a clause or condition to the covered transaction with that person or entity Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with this finding. The Foundation agrees with the recommendations of the auditors and has already prepared a draft policy regarding suspension and debarment. The CBF also confirmed that the one vendor who was not formally cleared in advance of her contract being executed, a longtime partner of the CBF, is able to receive federal funds.