Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-002 ? Cash Management and Reporting Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Condition: The District has not filed the required quarterly reports since March 2022 for grant #200-210475, #223-210475, #224-210475, and #225-210475 which in turn resulted in PDE halting payments and placing these grants in suspension of payment/delinquent quarterly report status. The District has not filed the required quarterly reports since March 2022 for grant #181-212477 in a timely manner within the 10-day requirement. Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports timely, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed. Identification of Repeat Finding: No Questioned Costs: None Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. Management Response: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods, and that the information reported has been properly calculated based upon properly calculated and adjusted monthly revenues and expenditures.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 U.S. Department of Education Pass-Through Entity ? Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. Consistent with 2 CFR ? 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.