Audit 23374

Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.320 requires, among other things, that specific criteria be met for the procurement of noncompetitive proposals. Procurement of noncompetitive proposals is procurement through solicitation of a proposal from only one source, also known as a sole source vendor. This method may only be used when one or more of the following circumstances apply: ? The item is available only from a single source. ? The purchase is in response to a public emergency that will not permit a delay resulting from the competitive process. ? The purchase is expressly authorized by awarding or pass-through agency in response to a written request from the non-Federal entity or after solicitation of a number of sources, competition is determined inadequate. Additionally, The Uniform Guidance federal regulations per 2 CFR section 200.320 also requires, among other things, that specific criteria be met for the procurement of professional services. Procurement of professional services are required to follow the following procedures: ? The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. ? Formal procurement methods require public advertising unless a non-competitive procurement can be used. To ensure compliance with these requirements, justification of the use of noncompetitive proposals and research on the availability from multiple sources must be documented. Documentation of authorization must be retained, and any initial solicitations from multiple sources which are concluded to be inadequate, and such reasoning must be documented. Universe/Population: The total population was all vendors of the Special Education Cluster whose transactions for the year ended June 30, 2022, exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the population. Based on these requirements, the population consisted of twenty-five vendors totaling $1,179,048. Conditions: Four vendors with expenditures totaling $451,259 were selected for testing. We noted one of the vendor selected for testing was deemed to be a sole source provider of hardware and software equipment by the School Board totaling $45,000. A sole source letter was obtained from the vendor, which outlined the uniqueness of the goods and services to be provided. However, it was determined that School Board did not appropriately follow the process for reviewing a sole source provider, per their federal procurement policy. Additionally, the form used by the School Board to document the justification of a sole source vendor was deemed insufficient for the following reasons: (1) an adequate analysis or comparison of like products was not properly completed and (2) the request form was not approved (i.e. no signature) by the purchasing department. For the remaining three vendors selected, we noted that payments were made for professional service in excess of procurement thresholds under Uniform Guidance which were not properly procured. Cause: The School Board did not adhere to its established procurement policy for professional services or noncompetitive proposals to sole source vendors and control and internal review process was not properly followed. Effect: Without proper internal controls over procurement to sole source or professional service vendors, the School Board may enter into contracts with vendors where the price may not be fair or reasonable. Recommendations: The School Board should strengthen controls at the program administration level to ensure appropriate consideration to competitors are given and adequate documentation is obtained with respect to procurement of professional services and sole source products in accordance with the Uniform Guidance 2 CFR section 200.320(f). This documentation should be approved by the program director, as well as the purchasing director, and retained as evidence of the internal controls over procurement.

Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.320 requires, among other things, that specific criteria be met for the procurement of noncompetitive proposals. Procurement of noncompetitive proposals is procurement through solicitation of a proposal from only one source, also known as a sole source vendor. This method may only be used when one or more of the following circumstances apply: ? The item is available only from a single source. ? The purchase is in response to a public emergency that will not permit a delay resulting from the competitive process. ? The purchase is expressly authorized by awarding or pass-through agency in response to a written request from the non-Federal entity or after solicitation of a number of sources, competition is determined inadequate. Additionally, The Uniform Guidance federal regulations per 2 CFR section 200.320 also requires, among other things, that specific criteria be met for the procurement of professional services. Procurement of professional services are required to follow the following procedures: ? The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. ? Formal procurement methods require public advertising unless a non-competitive procurement can be used. To ensure compliance with these requirements, justification of the use of noncompetitive proposals and research on the availability from multiple sources must be documented. Documentation of authorization must be retained, and any initial solicitations from multiple sources which are concluded to be inadequate, and such reasoning must be documented. Universe/Population: The total population was all vendors of the Special Education Cluster whose transactions for the year ended June 30, 2022, exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the population. Based on these requirements, the population consisted of twenty-five vendors totaling $1,179,048. Conditions: Four vendors with expenditures totaling $451,259 were selected for testing. We noted one of the vendor selected for testing was deemed to be a sole source provider of hardware and software equipment by the School Board totaling $45,000. A sole source letter was obtained from the vendor, which outlined the uniqueness of the goods and services to be provided. However, it was determined that School Board did not appropriately follow the process for reviewing a sole source provider, per their federal procurement policy. Additionally, the form used by the School Board to document the justification of a sole source vendor was deemed insufficient for the following reasons: (1) an adequate analysis or comparison of like products was not properly completed and (2) the request form was not approved (i.e. no signature) by the purchasing department. For the remaining three vendors selected, we noted that payments were made for professional service in excess of procurement thresholds under Uniform Guidance which were not properly procured. Cause: The School Board did not adhere to its established procurement policy for professional services or noncompetitive proposals to sole source vendors and control and internal review process was not properly followed. Effect: Without proper internal controls over procurement to sole source or professional service vendors, the School Board may enter into contracts with vendors where the price may not be fair or reasonable. Recommendations: The School Board should strengthen controls at the program administration level to ensure appropriate consideration to competitors are given and adequate documentation is obtained with respect to procurement of professional services and sole source products in accordance with the Uniform Guidance 2 CFR section 200.320(f). This documentation should be approved by the program director, as well as the purchasing director, and retained as evidence of the internal controls over procurement.

Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.320 requires, among other things, that specific criteria be met for the procurement of noncompetitive proposals. Procurement of noncompetitive proposals is procurement through solicitation of a proposal from only one source, also known as a sole source vendor. This method may only be used when one or more of the following circumstances apply: ? The item is available only from a single source. ? The purchase is in response to a public emergency that will not permit a delay resulting from the competitive process. ? The purchase is expressly authorized by awarding or pass-through agency in response to a written request from the non-Federal entity or after solicitation of a number of sources, competition is determined inadequate. Additionally, The Uniform Guidance federal regulations per 2 CFR section 200.320 also requires, among other things, that specific criteria be met for the procurement of professional services. Procurement of professional services are required to follow the following procedures: ? The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. ? Formal procurement methods require public advertising unless a non-competitive procurement can be used. To ensure compliance with these requirements, justification of the use of noncompetitive proposals and research on the availability from multiple sources must be documented. Documentation of authorization must be retained, and any initial solicitations from multiple sources which are concluded to be inadequate, and such reasoning must be documented. Universe/Population: The total population was all vendors of the Special Education Cluster whose transactions for the year ended June 30, 2022, exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the population. Based on these requirements, the population consisted of twenty-five vendors totaling $1,179,048. Conditions: Four vendors with expenditures totaling $451,259 were selected for testing. We noted one of the vendor selected for testing was deemed to be a sole source provider of hardware and software equipment by the School Board totaling $45,000. A sole source letter was obtained from the vendor, which outlined the uniqueness of the goods and services to be provided. However, it was determined that School Board did not appropriately follow the process for reviewing a sole source provider, per their federal procurement policy. Additionally, the form used by the School Board to document the justification of a sole source vendor was deemed insufficient for the following reasons: (1) an adequate analysis or comparison of like products was not properly completed and (2) the request form was not approved (i.e. no signature) by the purchasing department. For the remaining three vendors selected, we noted that payments were made for professional service in excess of procurement thresholds under Uniform Guidance which were not properly procured. Cause: The School Board did not adhere to its established procurement policy for professional services or noncompetitive proposals to sole source vendors and control and internal review process was not properly followed. Effect: Without proper internal controls over procurement to sole source or professional service vendors, the School Board may enter into contracts with vendors where the price may not be fair or reasonable. Recommendations: The School Board should strengthen controls at the program administration level to ensure appropriate consideration to competitors are given and adequate documentation is obtained with respect to procurement of professional services and sole source products in accordance with the Uniform Guidance 2 CFR section 200.320(f). This documentation should be approved by the program director, as well as the purchasing director, and retained as evidence of the internal controls over procurement.

Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.320 requires, among other things, that specific criteria be met for the procurement of noncompetitive proposals. Procurement of noncompetitive proposals is procurement through solicitation of a proposal from only one source, also known as a sole source vendor. This method may only be used when one or more of the following circumstances apply: ? The item is available only from a single source. ? The purchase is in response to a public emergency that will not permit a delay resulting from the competitive process. ? The purchase is expressly authorized by awarding or pass-through agency in response to a written request from the non-Federal entity or after solicitation of a number of sources, competition is determined inadequate. Additionally, The Uniform Guidance federal regulations per 2 CFR section 200.320 also requires, among other things, that specific criteria be met for the procurement of professional services. Procurement of professional services are required to follow the following procedures: ? The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. ? Formal procurement methods require public advertising unless a non-competitive procurement can be used. To ensure compliance with these requirements, justification of the use of noncompetitive proposals and research on the availability from multiple sources must be documented. Documentation of authorization must be retained, and any initial solicitations from multiple sources which are concluded to be inadequate, and such reasoning must be documented. Universe/Population: The total population was all vendors of the Special Education Cluster whose transactions for the year ended June 30, 2022, exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the population. Based on these requirements, the population consisted of twenty-five vendors totaling $1,179,048. Conditions: Four vendors with expenditures totaling $451,259 were selected for testing. We noted one of the vendor selected for testing was deemed to be a sole source provider of hardware and software equipment by the School Board totaling $45,000. A sole source letter was obtained from the vendor, which outlined the uniqueness of the goods and services to be provided. However, it was determined that School Board did not appropriately follow the process for reviewing a sole source provider, per their federal procurement policy. Additionally, the form used by the School Board to document the justification of a sole source vendor was deemed insufficient for the following reasons: (1) an adequate analysis or comparison of like products was not properly completed and (2) the request form was not approved (i.e. no signature) by the purchasing department. For the remaining three vendors selected, we noted that payments were made for professional service in excess of procurement thresholds under Uniform Guidance which were not properly procured. Cause: The School Board did not adhere to its established procurement policy for professional services or noncompetitive proposals to sole source vendors and control and internal review process was not properly followed. Effect: Without proper internal controls over procurement to sole source or professional service vendors, the School Board may enter into contracts with vendors where the price may not be fair or reasonable. Recommendations: The School Board should strengthen controls at the program administration level to ensure appropriate consideration to competitors are given and adequate documentation is obtained with respect to procurement of professional services and sole source products in accordance with the Uniform Guidance 2 CFR section 200.320(f). This documentation should be approved by the program director, as well as the purchasing director, and retained as evidence of the internal controls over procurement.