Finding Text
Federal agency: U.S. Department of Treasury
Federal program title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Period: March 3, 2021 – December 31, 2026
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
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 nonprocurement 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: The Village did not complete the suspension and debarment procedures prior to entering into the transactions.
Questioned costs: None
Context: The Village’s suspension and debarment policy has not been completely followed per the Uniform Grant Guidance. This was noted in the 2 out of 2 items tested.
Cause: The processes for suspension and debarment where updated and approved near the end of the current fiscal year as a result of the prior year finding. However, the updated procedures were not implemented for the full year which resulted in the majority of the current year’s transactions following the old procedures.
Effect: A lack of internal control procedures can lead to noncompliance with grant requirements.
Repeat finding: No
Recommendation: We recommend following the requirements for suspension and debarment per the Uniform Guidance, including the date performed and retain required documentation.
Views of responsible officials: The Village recognizes and accepts the audit finding as presented