Quay CountyLocal Government

2025-005—SUSPENSION AND DEBARMENT; Condition The County does not adequately document its review process to confirm vendor suspension and debarment status prior to entering into federally funded transactions.Criteria Per 2 CFR 180.300, entering into a covered transaction you must verify that the business is not excluded or disqualified by checking SAM exclusions, or collecting a certification form, or adding a clause or condition to the covered transaction. Cause The County has not developed or implemented procedures to address the federal program suspension and debarment documentation requirements under the Uniform Guidance. The County outsourced some of the contracts procurement and the third part was not able to provide proof of vendor check. However, during the fieldwork, the County personnel verified the vendor on sams.gov and no negative results were found. Effect Failing to adequately verify suspension and debarment could result in the County engaging federally funded vendors who are prohibited from participating in federal programs, potentially causing disallowed costs, repayment obligations, or the loss of future federal funding. Recommendation We recommend the County: • Update procurement policies promptly to fully comply with all applicable federal procurement guidelines. Note: the County has the suspension and debarment procurement rules in the policies but it is not clear who is responsible to apply/check the rules when third party is used to do the procurement steps • Establish and implement documented processes for verifying and recording suspension and debarment checks before engaging in covered transactions. • Provide ongoing training for procurement staff to ensure proper understanding and consistent application of federal procurement standards, specifically regarding suspension/debarment checks.