Finding 968929 (2023-007)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-04-08
Audit: 302827
Organization: Roosevelt County (MT)

AI Summary

  • Core Issue: The county failed to verify that its third-party suppliers and contractors are eligible for federal assistance, violating procurement rules.
  • Impacted Requirements: Non-compliance with Treasury’s Final Rule and 2 CFR 200.214 regarding debarred or suspended parties.
  • Recommended Follow-up: Establish a verification process using SAM Exclusions, collect certifications, or include clauses in contracts to ensure compliance.

Finding Text

CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, PROCUREMENT AND SUSPENSION AND DEBARMENT Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, recipients are prohibited from using SLFRF funds to enter into subawards and contracts with parties at a lower tier, (a contractor, subcontractor, individual or supplier) that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The county did not verify eligibility for participation in the federal program for its third-party suppliers and contractors. Questioned Costs: None Cause: The county does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions Recommendation: The county should develop a process to verify that all required parties are not suspended or debarred or otherwise excluded from participation in the federal program. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM, (2) collecting a certification from the entity, or (3) adding a clause or condition to the transaction with that entity (2 CFR section 180.300). Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached corrective action plan.

Categories

Procurement, Suspension & Debarment Eligibility

Other Findings in this Audit

  • 392487 2023-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $572,580
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $86,037
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $48,062
97.042 Emergency Management Performance Grants $44,916
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $41,849
93.069 Public Health Emergency Preparedness $34,585
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $30,850
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $29,336
97.067 Homeland Security Grant Program $15,662
93.994 Maternal and Child Health Services Block Grant to the States $12,343
10.664 Cooperative Forestry Assistance $6,000
93.052 National Family Caregiver Support, Title Iii, Part E $5,579
93.268 Immunization Cooperative Agreements $3,551