Finding 976367 (2022-004)

Suspension & Debarment (Significant Deficiency in Internal Controls over Compliance, Other Noncompliance) Federal Agency: U.S. Department of the Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing Number: 21.027 Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Post Federal Award Requirements and Cost Principles for Federal Award requires the grantee to perform suspension and debarment checks when procuring goods or services. Condition: For two procurements out of a population of seven tested for this program, the County did not perform the required suspension and debarment verification prior to entering into vendor agreements. Questioned Costs: None Cause: The County does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors. Effect: The County was not in compliance with federal award suspension and debarment requirements. Continued noncompliance can result in sanctions by the federal awarding agency, including withholding future funding. Repeat Finding: No Recommendation: The County should implement procedures to ensure the suspension and debarment check is completed prior to finalizing agreements with vendors. Views of responsible officials – Management agrees with this finding and recommendation. The County will implement a county-wide contract clause that will be added to covered transaction contracts to comply with 2 CFR 180, to ensure covered transactions receive verification that the person or entity is not excluded or disqualified. Review and approval of this suspension and debarment verification will be performed during the contract approval process, which will include this standardized clause. The County’s purchasing policy and procedures manual will be updated to include this standard suspension and debarment verification process to ensure this procedure is communicated county-wide and followed.