Finding Text
Federal Agency: U.S. Department of Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: Not available.
Pass-Through Agencies: Massachusetts Department of Administration and Finance; Bristol County
Pass-Through Number(s): Not Available
Award Period: March 3, 2021 through December 31, 2026
Compliance Requirement: Procurement, Suspension and Debarment
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matter
Criteria or specific requirement: Title 2 of the U.S. Code of Federal Regulations (CFR), Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement.
Condition: The Town did not obtain evidence supporting their verification that entities were not suspended, debarred, or otherwise excluded from participating in the grant award transactions.
Questioned costs: None.
Context: The Town did not obtain evidence of verification of the suspension and debarment status for three (3) of four (4) entities to which the Town incurred expenditures in excess of $25,000.
Cause: Internal controls were not implemented to ensure documented evidence was obtained regarding the suspension and debarment status for all entities receiving federal funds in excess of $25,000 from the Town.
Effect: The Town’s risk of noncompliance with the federal award program was elevated. It was later verified the entities in question were not suspended or debarred.
Repeat Finding: No.
Recommendation: We recommend the Town ensure documentation be obtained supporting the suspension and debarment status of entities to which the Town expends greater than $25,000. Such documentation could include (1) a history of searching SAM.gov exclusions, (2) certification from the entity, or (3) a clause or condition included in the contract or subaward with the entity.
Views of Responsible Officials: There is no disagreement with the audit finding.