Spencer Municipal Utilities

Procurement Suspension & Debarment Criteria – Title 2, U.S. Code of Federal Regulations Part 180.300 When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition – The Utility’s management did not verify that the vendor was not suspended or disbarred. Cause –The Utility’s management were not aware that they needed to verify that the entity was not suspended or debarred. Effect – The Utility did not have a process to indicate that the vendor was not suspended or disbarred from doing business with federal funds. The Utility is not in compliance with Federal regulations pertaining to procurement suspension & debarment as required by the Uniform Guidance. Recommendation – The Utility should verify that each vendor or contracts paid with federal awards, are not suspended by checking the System for Awards Management (SAM) Exclusion available at SAM.gov. Corrective Action – The Utility was unable to check to make sure the contractor was not disbarred from federal grants. The Utility is working through a process to ensure all contractors are not on the disbarred list. The Utility will check SAMS numbers and do more work on the front end for each contractor. Conclusion – Response accepted.

The Utility will adopt a policy to ensure that all vendors and contracts paid with federal awards, are not suspended or disbarred by verifying it on the SAM website.