One of the "strings" that comes with federal funding to state and local agencies is the requirement to check that contractors, consultants, and vendors are not debarred by, or suspended from doing business with, the federal government.
It's really a very simple requirement, but it is one of the most commonly overlooked requirements, resulting in frequent audit findings.
The Requirement: Here's what the Washington State Auditor's Office wrote about the requirement when issuing a recent finding to a conservation district:
"Recipients of federal grants are prohibited from contracting with or making subawards to parties that are suspended or debarred from doing business with the federal government. For vendor contracts of $25,000 or more and all subawards, the District must ensure the vendor or subrecipient is not suspended or debarred. This can be accomplished by obtaining a written certification from the vendor or subrecipient stating that its organization has not been suspended or debarred. Alternatively, the District may check for suspended or debarred parties by reviewing the federal Excluded Parties List issued by the U.S. General Services Administration. This requirement must be met prior to making the first payment to the vendors and subrecipeints."
Recent Audit Findings: The following public agencies recently received audit findings from the Washington State Auditor's Office for failing to monitor the suspension and debarment status of contractors on federally funded projects:
- Kitsap County Health District
- Benton County Emergency Services
- North Yakima Conservation District
- City of Anacortes
- City of Yakima
Checking for Debarment: The federal government's Excluded Parties List System (EPLS) may be accessed online at www.epls.gov to check the suspension and debarment status of any business. Be sure to print a copy of the results of this search and keep it in your contract file as documentation of compliance.
Mike Purdy's Public Contracting Blog© 2011 by Michael E. Purdy Associates, LLChttp://PublicContracting.blogspot.com
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