Finding Text
2023-004 – Procurement, Suspension and Debarment
Federal agency: U.S. Treasury
Federal program title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; Illinois Criminal Justice Information Authority
Pass-Through Number(s): 20220246 - 2023; 20220245 - 2023; 822007 - 2023
Award Period: 3/1/22-12/31/23; 3/1/22-12/31/23; 3/1/22-12/31/24; 4/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: CFR § 200.320 indicates the various methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and § 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. § 200.214 Suspension and debarment indicates non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate procurement process. Questioned costs: N/A
Context: 5 of 5 vendors selected for procurement testing, did not have documentation showing that the cost had been procured in accordance with the Uniform Guidance. Additionally, 2 of 2 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract.
Cause: Error by management in understanding Uniform Guidance requirements.
Effect: Lack of appropriate procurement, suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical.
Repeat Finding: No
Recommendation: We recommend the Organization revised its internal controls related to procurement, suspension and debarment such that they align with the requirements of the Uniform Guidance.
Views of responsible officials: The Organization is in the process of developing a procurement policy and suspension and debarment policies that aligns with Uniform Guidance.