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.