DAUPHIN COUNTY CONSERVATION DISTRICTLocal Government

Procurement and Suspension and Debarment. ALN 21.027 Coronavirus State and Local Fiscal Recovery Fund. Criteria: In accordance with 2 CFR §180.300, the District is required to perform procedures to ensure that contractors are neither suspended nor debarred prior to entering into a contract to procure goods and services. This may be accomplished by checking the System for Award Management Exclusions, collecting a certification from the entity, or adding a clause or condition to the contract with the entity. Condition: For 6 of the 6 contracts tested, we noted that the District entered into a contract without performing procedures to ensure that the entity was not suspended or debarred when the contract was executed. Cause: The District did not establish procedures to ensure a verification of suspension or debarment was performed prior to entering into a contract with vendors. Effect: Adequate internal controls are not in place over Federal Procurement and Suspension and Debarment compliance requirements and the District is not in compliance with the requirement. Questioned Costs: None. Recommendation: The District should design and implement procedures to ensure that contractors are neither suspended nor debarred prior to entering into a contract. Management's Response: The District agrees with the finding and will implement procedures to ensure that all future vendor contracts are not suspended nor debarred prior to contracting with them.

Reporting. ALN 21.027 Coronavirus State and Local Fiscal Recovery Fund. Criteria: Pursuant to 2 CFR part 200 section 303, the District is responsible for establishing and maintaining effective internal control over the Federal award that provides reasonable assurance that the District is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: All of the two reports selected for testing did not have sufficient audit evidence to demonstrate they were reviewed and approved prior to submission. Cause: Due to limited program staffing, reports were prepared directly by the Fiscal Coordinator and submitted to the grantor without an independent review. Effect: The District’s internal controls over this requirement were not operating effectively. Questioned Costs: None. Recommendation: The District should establish procedures to ensure reports are reviewed and approved prior to submission. Management's Response: The District agrees with the finding and will implement procedures that require a review and approval over reports, as demonstrated by the initials of the District Manager, prior to the submission of grant reports.