JACKSON TRANSIT AUTHORITYLocal Government

Criteria: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal 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 Authority did not have controls in place to document the proper review of one covered transaction for proper suspension and debarment prior to entering into the transaction. Cause: Management did not maintain documentation as required through 2 CFR section 180 to support the transaction was not entered into with a suspended or debarred third party. Effects: Failure to properly maintain documentation of the transaction does not allow for the verification that the test occurred prior to entering into the transaction. If the Authority were to enter into a transaction with an suspended or debarred party, the whole transaction could be disallowed and not be eligible for federal funding. Questioned Costs: Based on testing, the particular entity was noted to not be included in the listing maintained at SAM.gov and therefore, there are no questioned costs. Context: This was the only instance noted in testing and appears to be an isolated instance. Recommendation: We recommend the Authority ensure all covered transactions are properly reviewed for proper suspension and debarment compliance prior to entering into the transaction. There are three optional ways to accomplish this requirement, which are (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Views of Responsible Officials: We will ensure all covered transactions are properly reviewed and documentation maintained in the procurement files, prior to entering into future agreements.