Finding No. 2022-002 Significant Deficiency: Procurement, Suspension And Debarment ? Control Finding Federal Award Information: U.S. Department of Education, Special Education Cluster, passed through the Missouri Department of Elementary and Secondary Education ALN: 84.027 and 84.173 - Special Education Cluster Criteria: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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 is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Yes. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions. Views Of Responsible Officials: The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.
Finding No. 2022-002 Significant Deficiency: Procurement, Suspension And Debarment ? Control Finding Federal Award Information: U.S. Department of Education, Special Education Cluster, passed through the Missouri Department of Elementary and Secondary Education ALN: 84.027 and 84.173 - Special Education Cluster Criteria: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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 is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Yes. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions. Views Of Responsible Officials: The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.
Finding No. 2022-002 Significant Deficiency: Procurement, Suspension And Debarment ? Control Finding Federal Award Information: U.S. Department of Education, Special Education Cluster, passed through the Missouri Department of Elementary and Secondary Education ALN: 84.027 and 84.173 - Special Education Cluster Criteria: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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 is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Yes. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions. Views Of Responsible Officials: The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.
Finding 2022-003 Significant Deficiency: Equipment and Real Property Management ? Control Finding; Special Test and Provisions: Restricted Purpose - Control Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: The signed equipment use agreement related to the student?s remote connectivity was not retained. This agreement should be obtained for any student that checks out equipment through the District and retained. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that an ineligible student could receive wireless service through a connected device, or exceed the limit on the number of connected devices. Questioned Costs: Not applicable. Context: Internal controls as designed by the District were to ensure students signed the use agreement for equipment checked out. A signed use agreement was unable to be located for 21 out of 40 students tested for equipment and real property and special test and provision requirements. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The District will review and adjust the current process and make necessary adjustments to ensure each student with an ECF device will have the necessary documentation in their file. The District will also develop an additional contract to distinguish between an ECF device versus a regular district issued device.
Finding 2022-004 Significant Deficiency: Special Tests and Provisions: Restricted Purpose ? Control and Compliance Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: The compliance provisions of the federal program limit the amount of equipment that one student is able to have. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program related to special tests and provision requirements. Condition: For 6 of 40 students that checked out equipment, student profiles that stated if equipment was returned was unable to be provided. Cause: Controls over compliance put in place by management were not operating effectively as it relates to this compliance requirement. Effect: The possibility exists that a student could exceed the limit on the number of checked out connected devices as regulated by the federal agency. Questioned Costs: Not applicable. Context: Internal controls as designed by the District to ensure that per location and per user limits of equipment that is checked out by students is properly recorded in the system and tracked through the return process were not operating effectively. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The Information Technology Department will revise the current process for returning equipment so that if an ECF device is not returned, the student?s profile in SIS will reflect the type of device not returned and be issued a District on-site device only. The student?s profile for the ensuing fiscal year will then reflect that the student will be eligible for an on-site device District device only.
Finding 2022-005 Significant Deficiency: Period of Performance ? Control and Compliance Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: The compliance provisions of the federal program require that final expense reimbursements take place within 60 days of the last service date. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program related to special tests and provision requirements. Condition: Reimbursement request was not prepared and submitted until December 2022, even though 60 days after the last service date was August 2022. Cause: Management did not have an internal control process in place to ensure timely submission of the reimbursement request. Effect: The possibility exists that noncompliance with federal requirements could go undetected, and the federal agency could deny the request for reimbursement, without proper controls over compliance. Questioned Costs: Not applicable. Context: Reimbursement request was submitted in December 2022 and the federal agency funded the request in December 2022. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The Information Technology Department will provide all necessary grant paperwork to the Finance Office to ensure that all applicable deadlines are met, and that reimbursement happens in the allotted time period.
Finding No. 2022-002 Significant Deficiency: Procurement, Suspension And Debarment ? Control Finding Federal Award Information: U.S. Department of Education, Special Education Cluster, passed through the Missouri Department of Elementary and Secondary Education ALN: 84.027 and 84.173 - Special Education Cluster Criteria: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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 is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Yes. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions. Views Of Responsible Officials: The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.
Finding No. 2022-002 Significant Deficiency: Procurement, Suspension And Debarment ? Control Finding Federal Award Information: U.S. Department of Education, Special Education Cluster, passed through the Missouri Department of Elementary and Secondary Education ALN: 84.027 and 84.173 - Special Education Cluster Criteria: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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 is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Yes. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions. Views Of Responsible Officials: The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.
Finding No. 2022-002 Significant Deficiency: Procurement, Suspension And Debarment ? Control Finding Federal Award Information: U.S. Department of Education, Special Education Cluster, passed through the Missouri Department of Elementary and Secondary Education ALN: 84.027 and 84.173 - Special Education Cluster Criteria: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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 is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Yes. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions. Views Of Responsible Officials: The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.
Finding 2022-003 Significant Deficiency: Equipment and Real Property Management ? Control Finding; Special Test and Provisions: Restricted Purpose - Control Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: The signed equipment use agreement related to the student?s remote connectivity was not retained. This agreement should be obtained for any student that checks out equipment through the District and retained. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that an ineligible student could receive wireless service through a connected device, or exceed the limit on the number of connected devices. Questioned Costs: Not applicable. Context: Internal controls as designed by the District were to ensure students signed the use agreement for equipment checked out. A signed use agreement was unable to be located for 21 out of 40 students tested for equipment and real property and special test and provision requirements. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The District will review and adjust the current process and make necessary adjustments to ensure each student with an ECF device will have the necessary documentation in their file. The District will also develop an additional contract to distinguish between an ECF device versus a regular district issued device.
Finding 2022-004 Significant Deficiency: Special Tests and Provisions: Restricted Purpose ? Control and Compliance Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: The compliance provisions of the federal program limit the amount of equipment that one student is able to have. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program related to special tests and provision requirements. Condition: For 6 of 40 students that checked out equipment, student profiles that stated if equipment was returned was unable to be provided. Cause: Controls over compliance put in place by management were not operating effectively as it relates to this compliance requirement. Effect: The possibility exists that a student could exceed the limit on the number of checked out connected devices as regulated by the federal agency. Questioned Costs: Not applicable. Context: Internal controls as designed by the District to ensure that per location and per user limits of equipment that is checked out by students is properly recorded in the system and tracked through the return process were not operating effectively. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The Information Technology Department will revise the current process for returning equipment so that if an ECF device is not returned, the student?s profile in SIS will reflect the type of device not returned and be issued a District on-site device only. The student?s profile for the ensuing fiscal year will then reflect that the student will be eligible for an on-site device District device only.
Finding 2022-005 Significant Deficiency: Period of Performance ? Control and Compliance Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: The compliance provisions of the federal program require that final expense reimbursements take place within 60 days of the last service date. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program related to special tests and provision requirements. Condition: Reimbursement request was not prepared and submitted until December 2022, even though 60 days after the last service date was August 2022. Cause: Management did not have an internal control process in place to ensure timely submission of the reimbursement request. Effect: The possibility exists that noncompliance with federal requirements could go undetected, and the federal agency could deny the request for reimbursement, without proper controls over compliance. Questioned Costs: Not applicable. Context: Reimbursement request was submitted in December 2022 and the federal agency funded the request in December 2022. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The Information Technology Department will provide all necessary grant paperwork to the Finance Office to ensure that all applicable deadlines are met, and that reimbursement happens in the allotted time period.