Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to the following: the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Condition/context: Of the four procurement transactions subjected to testing, there were two professional service
contracts that the District did not have documentation supporting the sole source procurement method.
Cause: The District did not maintain proper sole source documentation for these vendors due to the unique
services provided.
Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms
and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional
conditions, as described in §200.208 Specific conditions. If the Federal awarding agency or pass-through entity
determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding
agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more
severe enforcement action by the Federal awarding agency or pass-through entity.
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the
activity or action not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal
awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: We recommend the Procurement policy be modified to more clearly state that documentation
will be maintained to identify the determination for sole-sourcing as described in 2 CFR 200.318 for all
professional service contracts over $2,500 (those requiring some kind of documentation to be maintained).
Furthermore, we recommend that contracting personnel be familiar with the specifics of the procurement policies
of the District.
Views of responsible officials: Management concurs with the finding. See Exhibit I for corrective action plan.
Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to the following: the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Condition/context: Of the four procurement transactions subjected to testing, there were two professional service
contracts that the District did not have documentation supporting the sole source procurement method.
Cause: The District did not maintain proper sole source documentation for these vendors due to the unique
services provided.
Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms
and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional
conditions, as described in §200.208 Specific conditions. If the Federal awarding agency or pass-through entity
determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding
agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more
severe enforcement action by the Federal awarding agency or pass-through entity.
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the
activity or action not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal
awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: We recommend the Procurement policy be modified to more clearly state that documentation
will be maintained to identify the determination for sole-sourcing as described in 2 CFR 200.318 for all
professional service contracts over $2,500 (those requiring some kind of documentation to be maintained).
Furthermore, we recommend that contracting personnel be familiar with the specifics of the procurement policies
of the District.
Views of responsible officials: Management concurs with the finding. See Exhibit I for corrective action plan.
Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to the following: the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Condition/context: Of the four procurement transactions subjected to testing, there were two professional service
contracts that the District did not have documentation supporting the sole source procurement method.
Cause: The District did not maintain proper sole source documentation for these vendors due to the unique
services provided.
Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms
and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional
conditions, as described in §200.208 Specific conditions. If the Federal awarding agency or pass-through entity
determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding
agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more
severe enforcement action by the Federal awarding agency or pass-through entity.
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the
activity or action not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal
awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: We recommend the Procurement policy be modified to more clearly state that documentation
will be maintained to identify the determination for sole-sourcing as described in 2 CFR 200.318 for all
professional service contracts over $2,500 (those requiring some kind of documentation to be maintained).
Furthermore, we recommend that contracting personnel be familiar with the specifics of the procurement policies
of the District.
Views of responsible officials: Management concurs with the finding. See Exhibit I for corrective action plan.
Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to the following: the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Condition/context: Of the four procurement transactions subjected to testing, there were two professional service
contracts that the District did not have documentation supporting the sole source procurement method.
Cause: The District did not maintain proper sole source documentation for these vendors due to the unique
services provided.
Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms
and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional
conditions, as described in §200.208 Specific conditions. If the Federal awarding agency or pass-through entity
determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding
agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more
severe enforcement action by the Federal awarding agency or pass-through entity.
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the
activity or action not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal
awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: We recommend the Procurement policy be modified to more clearly state that documentation
will be maintained to identify the determination for sole-sourcing as described in 2 CFR 200.318 for all
professional service contracts over $2,500 (those requiring some kind of documentation to be maintained).
Furthermore, we recommend that contracting personnel be familiar with the specifics of the procurement policies
of the District.
Views of responsible officials: Management concurs with the finding. See Exhibit I for corrective action plan.
Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to the following: the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Condition/context: Of the four procurement transactions subjected to testing, there were two professional service
contracts that the District did not have documentation supporting the sole source procurement method.
Cause: The District did not maintain proper sole source documentation for these vendors due to the unique
services provided.
Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms
and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional
conditions, as described in §200.208 Specific conditions. If the Federal awarding agency or pass-through entity
determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding
agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more
severe enforcement action by the Federal awarding agency or pass-through entity.
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the
activity or action not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal
awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: We recommend the Procurement policy be modified to more clearly state that documentation
will be maintained to identify the determination for sole-sourcing as described in 2 CFR 200.318 for all
professional service contracts over $2,500 (those requiring some kind of documentation to be maintained).
Furthermore, we recommend that contracting personnel be familiar with the specifics of the procurement policies
of the District.
Views of responsible officials: Management concurs with the finding. See Exhibit I for corrective action plan.
Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to the following: the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Condition/context: Of the four procurement transactions subjected to testing, there were two professional service
contracts that the District did not have documentation supporting the sole source procurement method.
Cause: The District did not maintain proper sole source documentation for these vendors due to the unique
services provided.
Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms
and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional
conditions, as described in §200.208 Specific conditions. If the Federal awarding agency or pass-through entity
determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding
agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more
severe enforcement action by the Federal awarding agency or pass-through entity.
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the
activity or action not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal
awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: We recommend the Procurement policy be modified to more clearly state that documentation
will be maintained to identify the determination for sole-sourcing as described in 2 CFR 200.318 for all
professional service contracts over $2,500 (those requiring some kind of documentation to be maintained).
Furthermore, we recommend that contracting personnel be familiar with the specifics of the procurement policies
of the District.
Views of responsible officials: Management concurs with the finding. See Exhibit I for corrective action plan.
Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to the following: the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Condition/context: Of the four procurement transactions subjected to testing, there were two professional service
contracts that the District did not have documentation supporting the sole source procurement method.
Cause: The District did not maintain proper sole source documentation for these vendors due to the unique
services provided.
Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms
and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional
conditions, as described in §200.208 Specific conditions. If the Federal awarding agency or pass-through entity
determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding
agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more
severe enforcement action by the Federal awarding agency or pass-through entity.
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the
activity or action not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal
awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: We recommend the Procurement policy be modified to more clearly state that documentation
will be maintained to identify the determination for sole-sourcing as described in 2 CFR 200.318 for all
professional service contracts over $2,500 (those requiring some kind of documentation to be maintained).
Furthermore, we recommend that contracting personnel be familiar with the specifics of the procurement policies
of the District.
Views of responsible officials: Management concurs with the finding. See Exhibit I for corrective action plan.
Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to the following: the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Condition/context: Of the four procurement transactions subjected to testing, there were two professional service
contracts that the District did not have documentation supporting the sole source procurement method.
Cause: The District did not maintain proper sole source documentation for these vendors due to the unique
services provided.
Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms
and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional
conditions, as described in §200.208 Specific conditions. If the Federal awarding agency or pass-through entity
determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding
agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more
severe enforcement action by the Federal awarding agency or pass-through entity.
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the
activity or action not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal
awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: We recommend the Procurement policy be modified to more clearly state that documentation
will be maintained to identify the determination for sole-sourcing as described in 2 CFR 200.318 for all
professional service contracts over $2,500 (those requiring some kind of documentation to be maintained).
Furthermore, we recommend that contracting personnel be familiar with the specifics of the procurement policies
of the District.
Views of responsible officials: Management concurs with the finding. See Exhibit I for corrective action plan.
Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to the following: the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Condition/context: Of the four procurement transactions subjected to testing, there were two professional service
contracts that the District did not have documentation supporting the sole source procurement method.
Cause: The District did not maintain proper sole source documentation for these vendors due to the unique
services provided.
Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms
and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional
conditions, as described in §200.208 Specific conditions. If the Federal awarding agency or pass-through entity
determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding
agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more
severe enforcement action by the Federal awarding agency or pass-through entity.
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the
activity or action not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal
awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: We recommend the Procurement policy be modified to more clearly state that documentation
will be maintained to identify the determination for sole-sourcing as described in 2 CFR 200.318 for all
professional service contracts over $2,500 (those requiring some kind of documentation to be maintained).
Furthermore, we recommend that contracting personnel be familiar with the specifics of the procurement policies
of the District.
Views of responsible officials: Management concurs with the finding. See Exhibit I for corrective action plan.
Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to the following: the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Condition/context: Of the four procurement transactions subjected to testing, there were two professional service
contracts that the District did not have documentation supporting the sole source procurement method.
Cause: The District did not maintain proper sole source documentation for these vendors due to the unique
services provided.
Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms
and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional
conditions, as described in §200.208 Specific conditions. If the Federal awarding agency or pass-through entity
determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding
agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more
severe enforcement action by the Federal awarding agency or pass-through entity.
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the
activity or action not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal
awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: We recommend the Procurement policy be modified to more clearly state that documentation
will be maintained to identify the determination for sole-sourcing as described in 2 CFR 200.318 for all
professional service contracts over $2,500 (those requiring some kind of documentation to be maintained).
Furthermore, we recommend that contracting personnel be familiar with the specifics of the procurement policies
of the District.
Views of responsible officials: Management concurs with the finding. See Exhibit I for corrective action plan.