City of Marshfield

ARPA – Suspension & Debarment Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: March 3, 2021 – December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Requirement: Procurement, Suspension & Debarment Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition: The City entered into a procurement transaction that exceeded the covered threshold and did not perform a search for suspension and debarment prior to approving the procurement transaction in accordance with 2 CFR section 180.220. The City subsequently performed a search and the vendor was not suspended or disbarred. Questioned Costs: None Context: The City did not perform a search for the two procurement transactions that exceeded the covered transaction threshold. Cause: The City did not have procedures implemented to ensure that the vendor was not suspended or debarred prior to entering into a procurement transaction. Instead the City was performing annual checks every fall. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: No Recommendation: We recommend the City revise its policies and procedures to ensure that documentation related to suspension and debarment be presented with the procurement action prior to approval. Views of Responsible Officials: Refer to the management response per the corrective action plan.

Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the City revise its policies and procedures to ensure that documentation related to suspension and debarment be presented with the procurement action prior to approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: City staff conducted a review of newly contracted vendors associated with STP Urban funds. These contracts were recently executed with various engineering firms. None of these firms appear on the federal debarment list as maintained on System for Award Management (SAM). Documentation of these reviews is recorded within the respective project files in the City’s enterprise business software. Management is establishing a monthly review procedure to cross-reference the vendor list against the SAM debarment database. The anticipated implementation date is July 31, 2025. To further mitigate risk and ensure continued compliance, Management recommends incorporating a Certification of Non-Debarment or Suspension Status into the City’s contract execution process. This document will be completed, signed, and submitted by any contractor receiving $25,000 or more in payments. Name(s) of the contact person(s) responsible for corrective action: Jennifer Selenske, Finance Director Planned completion date for corrective action plan: July 31, 2025