Finding Text
Suspension and Debarment
Federal Agency: U.S. Department of Transportation
Federal Program Name: Formula Grants for Rural Areas and Tribal Transit Program
Assistance Listing Number: 20.509
Federal Award Identification Number and Year: MO-2020-010-00, MO-2019-24-00, MO-2021-003-00,
MO18-X035, and MO-2023-002-00
Pass-Through Agency: Missouri Department of Transportation
Pass-Through Number(s): N/A
Award Period: 7/1/14-12/31/24
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or specific requirement: Verification that vendors were not suspended or debarred were not
retained.
Condition: During the audit 1 of 7 vendors Oats did not complete a sam.gov search to see if the
vendor is either suspended or debarred.
Questioned costs: None
Context: Oats could not provide evidence of the vendor search performed before entering into a
contract with the vendor.
Cause: Oats did not have effective internal controls over compliance in place to ensure that suspension
and debarment procedures were followed and documented.
Effect: Failure to properly approve contractors and maintain documentation may result in unallowable
costs being charged to the grant, or may result in federal funds being charged to the grant for activities
related to suspended or debarred vendors.
Repeat Finding: N/A
Recommendation: Oats should update and strengthen their procurement policy to match UG and DOL
guidelines, and create a policy for verifying vendors are not suspended, debarred, or otherwise
excluded per UG guidelines. The Organization should ensure these policies are followed for all vendors
and that documentation related to these policies are maintained.
Views of responsible officials: There is no disagreement with the audit finding.