Finding 960681 (2023-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-03-25

AI Summary

  • Core Issue: The Commission failed to maintain documentation verifying that four out of five vendors were not suspended or debarred before payment with federal funds.
  • Impacted Requirements: Compliance with 2 CFR Section 180.995, which mandates verification of vendor eligibility in covered transactions.
  • Recommended Follow-Up: Update policies to ensure proper documentation is kept for vendor verification prior to disbursement of federal funds.

Finding Text

2023 – 003 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: None Condition/Context: Four of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred. Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds. Effect: The Commission could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of Responsible Officials: Management agrees with the finding.

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 384236 2023-001
    Significant Deficiency Repeat
  • 384237 2023-002
    Significant Deficiency
  • 384238 2023-003
    Significant Deficiency
  • 384239 2023-003
    Significant Deficiency
  • 960678 2023-001
    Significant Deficiency Repeat
  • 960679 2023-002
    Significant Deficiency
  • 960680 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.752 Rural Econnectivity Pilot Program (b, E) $6.39M
21.027 Coronavirus State and Local Fiscal Recovery Funds $833,224
10.863 Community Connect Grant Program $313,417
32.002 Universal Service Fund - High Cost $18,905