Finding Text
Finding 2023‐003: U.S. Department of the Treasury
Federal Financial Assistance Listing 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Compliance Requirement: Procurement Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Controls over Compliance
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award.
Per 31 CFR 19.300, prior to enter in subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR § 19.300.
Condition: The County did not review two counselors to determine that they were not suspended, debarred, or otherwise excluded prior to entering into a transaction with them.
Cause: The County relied on the Department of Public Safety FSCT clearinghouse and review of licensing for review of suspension for the two counselors, but did not review the counselors individually.
Effect: Counselors could be suspended, debarred, or otherwise excluded, and the county would not be aware.
Questioned Costs: None
Context / Sampling: We tested 40 of 371 transactions subject to suspension and debarment in the SLFRF program.
Repeat Finding from Prior Year: No
Recommendation: The County should review all counselors for suspension and debarment similar to how they review all other vendors.
Views of Responsible Officials: Management agrees with the noted finding. Refer to Corrective Action Plan.