TOWN OF SNOWMASS VILLAGELocal Government

Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D ? Post Federal Award Requirements, Section 200.318 requires that a non-federal entity must use its own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal law and standards. Federal regulations 2 C.F.R. 180.220 state that a contract for goods or services is a covered transaction if awarded in a nonprocurement transaction and if the amount of the contract is expected to equal or exceed $25,000. Also, federal regulation 2. C.F.R. 180.300 requires that when a non-federal entity enters into a covered transaction with another entity, the non-federal entity must verify that the person or entity they intend to do business with is not excluded or disqualified from receiving federal funds. This can be performed by: (1) checking the System of Award Management (SAM) exclusions, (2) collecting a certification from that entity, or (3) adding a clause or condition to the covered transaction with that person. Condition: The Town?s procurement policy documents the requirement to obtain and maintain proof that the vendor is not suspended or debarred prior to entering into a transaction. We tested internal controls over procurement, suspension and debarment for the grant and noted that there was no documentation to support two procurement transactions to two separate vendors (related to the SAM?s check being performed to determine if the vendor was debarred or suspended). Although there was no documentation to support the internal control was in place, we noted that the vendors were not suspended or debarred. Cause: The Town did not have controls in place to ensure that the policy was followed for all purchases resulting in the failure to perform verification prior to entering into a procurement transaction. Internal controls were not sufficient to ensure the required verification was performed. Effect: The failure to perform the SAM?s check may result in entering into a contract with a suspended or debarred entity. Questioned Costs: None reported Context/Sampling: A non-statistical sample of 10 expenditures subject to procurement out of approximately 60 total transactions were selected for procurement, suspension & debarment testing. Only two of the 10 transactions were greater than $25,000 of which suspension and debarment checks were required. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Town comply with their policy and conduct suspension and debarment checks for covered transactions prior to procurement on an annual basis. Views of Responsible Officials: Agree.