Finding 7974 (2023-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-01-09
Audit: 10415
Organization: Pershing County, Nevada (NV)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: Pershing County failed to verify suspension and debarment status before entering into contracts under federal awards.
  • Impacted Requirements: This violates Title 2 CFR Part 200, which mandates that contracts include specific provisions and verify that parties are not suspended or debarred.
  • Recommended Follow-Up: Enhance internal controls to ensure compliance with suspension and debarment verification for all federal award contracts.

Finding Text

U.S. Department of Treasury COVID-19 Coronavirus State and Local Fiscal Recovery Funds, 21.027 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires contracts contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Non-federal entities are prohibited from contracting under covered transactions to parties that are suspended or debarred. Non-federal entities may verify that a party is not suspended or debarred by checking the Excluded Parties List System, collecting a certification from the entity, or adding a clause or condition to the covered transaction vehicle. (2 CFR 200.214, 2 CFR Part 180). Condition: Suspension and debarment verification procedures were not performed prior to entering into covered transactions. Cause: Pershing County did not have adequate internal controls to ensure suspension and debarment verification procedures were performed prior to entering into all covered transactions. Effect: Contractors may not be aware of required terms and conditions and payments could be made to recipients who are suspended or debarred. Questioned Costs: None. Context/Sampling: The total population of two contracts subject to suspension and debarment verification procedures were selected for testing. Suspension and debarment procedures were not performed for either contract. Repeat Finding from Prior Year: No. Recommendation: We recommend the County enhance internal controls to ensure all contracts under federal awards contain the applicable provisions related to suspension and debarment or other procedures are performed to verify that the party is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Finding 2023-002 Finding Summary: Suspension and Debarment Verification Procedures were not performed prior to entering into covered transactions. Responsible Individual: Robert Bryce Shields, District Attorney Corrective Action Plan: Pershing County District Attorney’s Office will enhance Internal Controls to ensure all contracts under Federal Awards contain the applicable provisions related to Suspension and Debarment or other procedures are performed to verify that the party is not suspended or debarred. Anticipated Date of Correction Action Plan: Corrected November 14, 2023

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 7975 2023-002
    Significant Deficiency
  • 584416 2023-002
    Significant Deficiency
  • 584417 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $391,975
93.563 Child Support Enforcement $161,768
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $94,456
16.034 Coronavirus Emergency Supplemental Funding Program $79,404
16.540 Juvenile Justice and Delinquency Prevention_allocation to States $27,990
21.027 Coronavirus State and Local Fiscal Recovery Funds $20,000
97.042 Emergency Management Performance Grants $14,983
93.053 Nutrition Services Incentive Program $11,928
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $11,321
45.310 Grants to States $4,700
20.106 Airport Improvement Program $3,967
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $3,873
20.600 State and Community Highway Safety $1,790