Town of Winchester

FINDING 2025-001 – SIGNIFICANT DEFICIENCY- PROCUREMENT AND SUSPENSION AND DEBARMENT- INTERNAL CONTROL OVER VERIFICATION AGAINST THE SYSTEM FOR AWARD MANAGEMENT (“SAM”) Federal Agency: Environmental Protection Agency Federal Program Name: Clean Water State Revolving Fund Cluster Assistance Listing Number: 66.468 Pass-Through Agency: State of Connecticut Department of Public Health Pass-Through Number(s): 12060-DPH48770-23155, 12060-DPH48770-23149, 21018- DPH48770-42319 Compliance Requirement: Procurement and Suspension and Debarment Criteria 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are required to ensure that they do not award contracts or make subawards to any parties that are suspended or debarred from receiving federal funds. This verification may be accomplished by checking the System for Award Management (SAM). Condition The Town did not verify that vendors were not suspended or debarred by checking the System for Award Management (SAM). Context The Town recently updated its purchasing policies to include checking vendors for suspension/debarment on sam.gov, however, did not verify them under this grant program. None of the vendors selected for testing were suspended or debarred. Cause As the funding was passed through a State agency, the Town had mistakenly considered it State funding and did not check the vendors for suspension/debarment. Effect Failure to verify suspension and debarment status of parties engaged in federal transactions may result in noncompliance with federal regulations, leading to the risk of making awards to ineligible parties. Recommendation We recommend that the Town follows their recently adopted policies and procedures related to suspension/debarment to ensure compliance with federal requirements. The Town should verify, prior to awarding any federal contract or subaward, that the vendor, contractor, or subrecipient is not listed on the SAM exclusions list or any other relevant suspension and debarment lists and document that the verification process was performed and maintain supporting documentation. Views of Responsible Officials and Planned Corrective Actions The Town will ensure vendors are not suspended or debarred by checking the System for Award Management (SAM), and maintain documentation showing that verification.

AND DEBARMENT- INTERNAL CONTROL OVER VERIFICATION AGAINST THE SYSTEM FOR AWARD MANAGEMENT (“SAM”) Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Compliance Requirement: Procurement and Suspension and Debarment Criteria 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are required to ensure that they do not award contracts or make subawards to any parties that are suspended or debarred from receiving federal funds. This verification may be accomplished by checking the System for Award Management (SAM). Condition The Town did not have a process in place to check that vendors were not suspended or debarred by checking the System for Award Management (SAM). Context There was no process in place to verify that vendors are not suspended or debarred, however, none of the vendors selected for testing were suspended or debarred. Cause The Towns procurement and compliance procedures did not include a process for checking and verifying suspension and debarment status of vendors at the time of award or at periodic intervals afterwards. Effect Failure to verify suspension and debarment status of parties engaged in federal transactions may result in noncompliance with federal regulations, leading to the risk of making awards to ineligible parties. Recommendation We recommend that the Town establish and implement policies and procedures to ensure compliance with suspension and debarment requirements. The Town should establish procedures to verify, prior to awarding any federal contract or subaward, that the vendor, contractor, or subrecipient is not listed on the SAM exclusions list or any other relevant suspension and debarment lists. Implement a periodic review process to ensure that current vendors, contractors, and subrecipients remain eligible and are not suspended or debarred. Document that the verification process was performed and maintain supporting documentation. Views of Responsible Officials and Planned Corrective Actions The Town will establish policies and procedures to ensure vendors are not suspended or debarred by checking the System for Award Management (SAM), and maintain documentation showing that verification.