Finding 626420 (2022-002)

Finding Type. Immaterial Noncompliance (Procurement, Suspension and Debarment). Programs. Coronavirus State and Local Fiscal Recovery Funds; ALN 21.027. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the federal government by searching the vendor on Sam.gov. Such procedures are required whenever the amount disbursed to a single vendor in a given fiscal year is expected to be at least $25,000. These requirements are also applicable for subrecipients, regardless of the amount passed through. Condition. The County did not complete the process of checking Sam.gov for each vendor with disbursements over $25,000. Cause. This condition appears to have been caused by a lack of complete knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the County was exposed to an increased risk that disbursements of federal awards could be made to vendors or subrecipients suspended or debarred by the federal government. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors or subrecipients involved were actually suspended or debarred. Recommendation. We recommend that all employees administering federal grants and having primary responsibility for compliance with grant requirements be provided the necessary training and supervision to be able to identify and comply with such requirements. View of Responsible Officials. In the County?s attempt to address this finding through a centralized method of suspension/debarment verification, it was found that only vendor-specific requests can be made in the Federal system, as the Federal government does not allow vendor searches by tax identification number to be performed due to tax identification security concerns. As a result, a process is being developed for departments to perform necessary verifications of potential vendors and subrecipients, with centralized storage of verification documentation.