2023-001 – Procurement and Suspension and Debarment
Information on Federal Program
Federal Grantor: U.S. Department of Education
Pass-through Grantor: Pennsylvania Department of Education
Program: Early Intervention (Philadelphia), Early Intervention (Chester)
Assistance Listing #: 84.027, 84.173
Title: Special Education Cluster (IDEA)
Audit Period: 07/01/2022 – 06/30/2023
Passthrough Numbers: 232-210026, 231-210026, 232-210035, 231-210035
Criteria or Specific Requirement - Procurement guidance is located in sections 2 CFR 200.317-200.326 of Uniform Guidance focusing on increased competition and transparency in the procurement process. There are five general procurement standards covering the purchase of property, supplies and services under the Uniform Guidance as follows: (a) Costs must be reasonable and necessary, (b) must provide for full and open competition, (c) an organization must maintain written standards of conduct covering internal and external conflicts of interest, and (d) the organization must maintain documentation addressing cost and price analysis and vendor selections where applicable based on the method of procurement used. The non-Federal entity must use one of the following methods of procurement: (a) micro-purchases, (b) small purchases, (c) sealed bids, (d) competitive proposals or (e) sole source.
Condition - We noted for all of the eight procurements sampled, Elwyn did not provide a contemporaneously documented written conclusion on the method of each procurement that either demonstrated the procurements were conducted in a manner that provided full and open competition, or documented why noncompetitive procurement was appropriate. Elwyn provided their rationale for each of the procurements as part of the audit sample and testing process.
Cause - Policies and procedures were not appropriately adhered to sufficiently document rationale and to ensure that procurement method selected was supported.
Effect or Potential Effect - Written documentation insufficiently detailing the method and conclusions involved in procurement decisions, impacts the ability to demonstrate that full and open competition occurred, or that noncompetitive procurement was appropriate.
Questioned Costs - None
Context - We tested a sample of eight procurement transactions and noted that the Organization did not maintain contemporaneously written documentation and conclusions as required by its procurement policy for the selected items.
Repeat Finding - No
Recommendation - We recommend Elwyn enforce its existing policy and procedures to ensure compliance with procurement requirements. Elwyn should provide targeted training to members of the Organization involved in procurement processes on its existing policy and procedures to ensure understanding of the Organization’s requirements for documentation of procurement methods. Additionally, Elwyn should ensure all procurement decisions are contemporaneously documented with the information necessary to conclude on appropriateness of the procurement with respect to the procurement policy and requirements.
Views of Responsible Officials - Management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the lapses in internal control.
2023-001 – Procurement and Suspension and Debarment
Information on Federal Program
Federal Grantor: U.S. Department of Education
Pass-through Grantor: Pennsylvania Department of Education
Program: Early Intervention (Philadelphia), Early Intervention (Chester)
Assistance Listing #: 84.027, 84.173
Title: Special Education Cluster (IDEA)
Audit Period: 07/01/2022 – 06/30/2023
Passthrough Numbers: 232-210026, 231-210026, 232-210035, 231-210035
Criteria or Specific Requirement - Procurement guidance is located in sections 2 CFR 200.317-200.326 of Uniform Guidance focusing on increased competition and transparency in the procurement process. There are five general procurement standards covering the purchase of property, supplies and services under the Uniform Guidance as follows: (a) Costs must be reasonable and necessary, (b) must provide for full and open competition, (c) an organization must maintain written standards of conduct covering internal and external conflicts of interest, and (d) the organization must maintain documentation addressing cost and price analysis and vendor selections where applicable based on the method of procurement used. The non-Federal entity must use one of the following methods of procurement: (a) micro-purchases, (b) small purchases, (c) sealed bids, (d) competitive proposals or (e) sole source.
Condition - We noted for all of the eight procurements sampled, Elwyn did not provide a contemporaneously documented written conclusion on the method of each procurement that either demonstrated the procurements were conducted in a manner that provided full and open competition, or documented why noncompetitive procurement was appropriate. Elwyn provided their rationale for each of the procurements as part of the audit sample and testing process.
Cause - Policies and procedures were not appropriately adhered to sufficiently document rationale and to ensure that procurement method selected was supported.
Effect or Potential Effect - Written documentation insufficiently detailing the method and conclusions involved in procurement decisions, impacts the ability to demonstrate that full and open competition occurred, or that noncompetitive procurement was appropriate.
Questioned Costs - None
Context - We tested a sample of eight procurement transactions and noted that the Organization did not maintain contemporaneously written documentation and conclusions as required by its procurement policy for the selected items.
Repeat Finding - No
Recommendation - We recommend Elwyn enforce its existing policy and procedures to ensure compliance with procurement requirements. Elwyn should provide targeted training to members of the Organization involved in procurement processes on its existing policy and procedures to ensure understanding of the Organization’s requirements for documentation of procurement methods. Additionally, Elwyn should ensure all procurement decisions are contemporaneously documented with the information necessary to conclude on appropriateness of the procurement with respect to the procurement policy and requirements.
Views of Responsible Officials - Management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the lapses in internal control.
2023-001 – Procurement and Suspension and Debarment
Information on Federal Program
Federal Grantor: U.S. Department of Education
Pass-through Grantor: Pennsylvania Department of Education
Program: Early Intervention (Philadelphia), Early Intervention (Chester)
Assistance Listing #: 84.027, 84.173
Title: Special Education Cluster (IDEA)
Audit Period: 07/01/2022 – 06/30/2023
Passthrough Numbers: 232-210026, 231-210026, 232-210035, 231-210035
Criteria or Specific Requirement - Procurement guidance is located in sections 2 CFR 200.317-200.326 of Uniform Guidance focusing on increased competition and transparency in the procurement process. There are five general procurement standards covering the purchase of property, supplies and services under the Uniform Guidance as follows: (a) Costs must be reasonable and necessary, (b) must provide for full and open competition, (c) an organization must maintain written standards of conduct covering internal and external conflicts of interest, and (d) the organization must maintain documentation addressing cost and price analysis and vendor selections where applicable based on the method of procurement used. The non-Federal entity must use one of the following methods of procurement: (a) micro-purchases, (b) small purchases, (c) sealed bids, (d) competitive proposals or (e) sole source.
Condition - We noted for all of the eight procurements sampled, Elwyn did not provide a contemporaneously documented written conclusion on the method of each procurement that either demonstrated the procurements were conducted in a manner that provided full and open competition, or documented why noncompetitive procurement was appropriate. Elwyn provided their rationale for each of the procurements as part of the audit sample and testing process.
Cause - Policies and procedures were not appropriately adhered to sufficiently document rationale and to ensure that procurement method selected was supported.
Effect or Potential Effect - Written documentation insufficiently detailing the method and conclusions involved in procurement decisions, impacts the ability to demonstrate that full and open competition occurred, or that noncompetitive procurement was appropriate.
Questioned Costs - None
Context - We tested a sample of eight procurement transactions and noted that the Organization did not maintain contemporaneously written documentation and conclusions as required by its procurement policy for the selected items.
Repeat Finding - No
Recommendation - We recommend Elwyn enforce its existing policy and procedures to ensure compliance with procurement requirements. Elwyn should provide targeted training to members of the Organization involved in procurement processes on its existing policy and procedures to ensure understanding of the Organization’s requirements for documentation of procurement methods. Additionally, Elwyn should ensure all procurement decisions are contemporaneously documented with the information necessary to conclude on appropriateness of the procurement with respect to the procurement policy and requirements.
Views of Responsible Officials - Management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the lapses in internal control.
2023-001 – Procurement and Suspension and Debarment
Information on Federal Program
Federal Grantor: U.S. Department of Education
Pass-through Grantor: Pennsylvania Department of Education
Program: Early Intervention (Philadelphia), Early Intervention (Chester)
Assistance Listing #: 84.027, 84.173
Title: Special Education Cluster (IDEA)
Audit Period: 07/01/2022 – 06/30/2023
Passthrough Numbers: 232-210026, 231-210026, 232-210035, 231-210035
Criteria or Specific Requirement - Procurement guidance is located in sections 2 CFR 200.317-200.326 of Uniform Guidance focusing on increased competition and transparency in the procurement process. There are five general procurement standards covering the purchase of property, supplies and services under the Uniform Guidance as follows: (a) Costs must be reasonable and necessary, (b) must provide for full and open competition, (c) an organization must maintain written standards of conduct covering internal and external conflicts of interest, and (d) the organization must maintain documentation addressing cost and price analysis and vendor selections where applicable based on the method of procurement used. The non-Federal entity must use one of the following methods of procurement: (a) micro-purchases, (b) small purchases, (c) sealed bids, (d) competitive proposals or (e) sole source.
Condition - We noted for all of the eight procurements sampled, Elwyn did not provide a contemporaneously documented written conclusion on the method of each procurement that either demonstrated the procurements were conducted in a manner that provided full and open competition, or documented why noncompetitive procurement was appropriate. Elwyn provided their rationale for each of the procurements as part of the audit sample and testing process.
Cause - Policies and procedures were not appropriately adhered to sufficiently document rationale and to ensure that procurement method selected was supported.
Effect or Potential Effect - Written documentation insufficiently detailing the method and conclusions involved in procurement decisions, impacts the ability to demonstrate that full and open competition occurred, or that noncompetitive procurement was appropriate.
Questioned Costs - None
Context - We tested a sample of eight procurement transactions and noted that the Organization did not maintain contemporaneously written documentation and conclusions as required by its procurement policy for the selected items.
Repeat Finding - No
Recommendation - We recommend Elwyn enforce its existing policy and procedures to ensure compliance with procurement requirements. Elwyn should provide targeted training to members of the Organization involved in procurement processes on its existing policy and procedures to ensure understanding of the Organization’s requirements for documentation of procurement methods. Additionally, Elwyn should ensure all procurement decisions are contemporaneously documented with the information necessary to conclude on appropriateness of the procurement with respect to the procurement policy and requirements.
Views of Responsible Officials - Management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the lapses in internal control.
2023-001 – Procurement and Suspension and Debarment
Information on Federal Program
Federal Grantor: U.S. Department of Education
Pass-through Grantor: Pennsylvania Department of Education
Program: Early Intervention (Philadelphia), Early Intervention (Chester)
Assistance Listing #: 84.027, 84.173
Title: Special Education Cluster (IDEA)
Audit Period: 07/01/2022 – 06/30/2023
Passthrough Numbers: 232-210026, 231-210026, 232-210035, 231-210035
Criteria or Specific Requirement - Procurement guidance is located in sections 2 CFR 200.317-200.326 of Uniform Guidance focusing on increased competition and transparency in the procurement process. There are five general procurement standards covering the purchase of property, supplies and services under the Uniform Guidance as follows: (a) Costs must be reasonable and necessary, (b) must provide for full and open competition, (c) an organization must maintain written standards of conduct covering internal and external conflicts of interest, and (d) the organization must maintain documentation addressing cost and price analysis and vendor selections where applicable based on the method of procurement used. The non-Federal entity must use one of the following methods of procurement: (a) micro-purchases, (b) small purchases, (c) sealed bids, (d) competitive proposals or (e) sole source.
Condition - We noted for all of the eight procurements sampled, Elwyn did not provide a contemporaneously documented written conclusion on the method of each procurement that either demonstrated the procurements were conducted in a manner that provided full and open competition, or documented why noncompetitive procurement was appropriate. Elwyn provided their rationale for each of the procurements as part of the audit sample and testing process.
Cause - Policies and procedures were not appropriately adhered to sufficiently document rationale and to ensure that procurement method selected was supported.
Effect or Potential Effect - Written documentation insufficiently detailing the method and conclusions involved in procurement decisions, impacts the ability to demonstrate that full and open competition occurred, or that noncompetitive procurement was appropriate.
Questioned Costs - None
Context - We tested a sample of eight procurement transactions and noted that the Organization did not maintain contemporaneously written documentation and conclusions as required by its procurement policy for the selected items.
Repeat Finding - No
Recommendation - We recommend Elwyn enforce its existing policy and procedures to ensure compliance with procurement requirements. Elwyn should provide targeted training to members of the Organization involved in procurement processes on its existing policy and procedures to ensure understanding of the Organization’s requirements for documentation of procurement methods. Additionally, Elwyn should ensure all procurement decisions are contemporaneously documented with the information necessary to conclude on appropriateness of the procurement with respect to the procurement policy and requirements.
Views of Responsible Officials - Management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the lapses in internal control.
2023-001 – Procurement and Suspension and Debarment
Information on Federal Program
Federal Grantor: U.S. Department of Education
Pass-through Grantor: Pennsylvania Department of Education
Program: Early Intervention (Philadelphia), Early Intervention (Chester)
Assistance Listing #: 84.027, 84.173
Title: Special Education Cluster (IDEA)
Audit Period: 07/01/2022 – 06/30/2023
Passthrough Numbers: 232-210026, 231-210026, 232-210035, 231-210035
Criteria or Specific Requirement - Procurement guidance is located in sections 2 CFR 200.317-200.326 of Uniform Guidance focusing on increased competition and transparency in the procurement process. There are five general procurement standards covering the purchase of property, supplies and services under the Uniform Guidance as follows: (a) Costs must be reasonable and necessary, (b) must provide for full and open competition, (c) an organization must maintain written standards of conduct covering internal and external conflicts of interest, and (d) the organization must maintain documentation addressing cost and price analysis and vendor selections where applicable based on the method of procurement used. The non-Federal entity must use one of the following methods of procurement: (a) micro-purchases, (b) small purchases, (c) sealed bids, (d) competitive proposals or (e) sole source.
Condition - We noted for all of the eight procurements sampled, Elwyn did not provide a contemporaneously documented written conclusion on the method of each procurement that either demonstrated the procurements were conducted in a manner that provided full and open competition, or documented why noncompetitive procurement was appropriate. Elwyn provided their rationale for each of the procurements as part of the audit sample and testing process.
Cause - Policies and procedures were not appropriately adhered to sufficiently document rationale and to ensure that procurement method selected was supported.
Effect or Potential Effect - Written documentation insufficiently detailing the method and conclusions involved in procurement decisions, impacts the ability to demonstrate that full and open competition occurred, or that noncompetitive procurement was appropriate.
Questioned Costs - None
Context - We tested a sample of eight procurement transactions and noted that the Organization did not maintain contemporaneously written documentation and conclusions as required by its procurement policy for the selected items.
Repeat Finding - No
Recommendation - We recommend Elwyn enforce its existing policy and procedures to ensure compliance with procurement requirements. Elwyn should provide targeted training to members of the Organization involved in procurement processes on its existing policy and procedures to ensure understanding of the Organization’s requirements for documentation of procurement methods. Additionally, Elwyn should ensure all procurement decisions are contemporaneously documented with the information necessary to conclude on appropriateness of the procurement with respect to the procurement policy and requirements.
Views of Responsible Officials - Management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the lapses in internal control.
2023-001 – Procurement and Suspension and Debarment
Information on Federal Program
Federal Grantor: U.S. Department of Education
Pass-through Grantor: Pennsylvania Department of Education
Program: Early Intervention (Philadelphia), Early Intervention (Chester)
Assistance Listing #: 84.027, 84.173
Title: Special Education Cluster (IDEA)
Audit Period: 07/01/2022 – 06/30/2023
Passthrough Numbers: 232-210026, 231-210026, 232-210035, 231-210035
Criteria or Specific Requirement - Procurement guidance is located in sections 2 CFR 200.317-200.326 of Uniform Guidance focusing on increased competition and transparency in the procurement process. There are five general procurement standards covering the purchase of property, supplies and services under the Uniform Guidance as follows: (a) Costs must be reasonable and necessary, (b) must provide for full and open competition, (c) an organization must maintain written standards of conduct covering internal and external conflicts of interest, and (d) the organization must maintain documentation addressing cost and price analysis and vendor selections where applicable based on the method of procurement used. The non-Federal entity must use one of the following methods of procurement: (a) micro-purchases, (b) small purchases, (c) sealed bids, (d) competitive proposals or (e) sole source.
Condition - We noted for all of the eight procurements sampled, Elwyn did not provide a contemporaneously documented written conclusion on the method of each procurement that either demonstrated the procurements were conducted in a manner that provided full and open competition, or documented why noncompetitive procurement was appropriate. Elwyn provided their rationale for each of the procurements as part of the audit sample and testing process.
Cause - Policies and procedures were not appropriately adhered to sufficiently document rationale and to ensure that procurement method selected was supported.
Effect or Potential Effect - Written documentation insufficiently detailing the method and conclusions involved in procurement decisions, impacts the ability to demonstrate that full and open competition occurred, or that noncompetitive procurement was appropriate.
Questioned Costs - None
Context - We tested a sample of eight procurement transactions and noted that the Organization did not maintain contemporaneously written documentation and conclusions as required by its procurement policy for the selected items.
Repeat Finding - No
Recommendation - We recommend Elwyn enforce its existing policy and procedures to ensure compliance with procurement requirements. Elwyn should provide targeted training to members of the Organization involved in procurement processes on its existing policy and procedures to ensure understanding of the Organization’s requirements for documentation of procurement methods. Additionally, Elwyn should ensure all procurement decisions are contemporaneously documented with the information necessary to conclude on appropriateness of the procurement with respect to the procurement policy and requirements.
Views of Responsible Officials - Management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the lapses in internal control.
2023-001 – Procurement and Suspension and Debarment
Information on Federal Program
Federal Grantor: U.S. Department of Education
Pass-through Grantor: Pennsylvania Department of Education
Program: Early Intervention (Philadelphia), Early Intervention (Chester)
Assistance Listing #: 84.027, 84.173
Title: Special Education Cluster (IDEA)
Audit Period: 07/01/2022 – 06/30/2023
Passthrough Numbers: 232-210026, 231-210026, 232-210035, 231-210035
Criteria or Specific Requirement - Procurement guidance is located in sections 2 CFR 200.317-200.326 of Uniform Guidance focusing on increased competition and transparency in the procurement process. There are five general procurement standards covering the purchase of property, supplies and services under the Uniform Guidance as follows: (a) Costs must be reasonable and necessary, (b) must provide for full and open competition, (c) an organization must maintain written standards of conduct covering internal and external conflicts of interest, and (d) the organization must maintain documentation addressing cost and price analysis and vendor selections where applicable based on the method of procurement used. The non-Federal entity must use one of the following methods of procurement: (a) micro-purchases, (b) small purchases, (c) sealed bids, (d) competitive proposals or (e) sole source.
Condition - We noted for all of the eight procurements sampled, Elwyn did not provide a contemporaneously documented written conclusion on the method of each procurement that either demonstrated the procurements were conducted in a manner that provided full and open competition, or documented why noncompetitive procurement was appropriate. Elwyn provided their rationale for each of the procurements as part of the audit sample and testing process.
Cause - Policies and procedures were not appropriately adhered to sufficiently document rationale and to ensure that procurement method selected was supported.
Effect or Potential Effect - Written documentation insufficiently detailing the method and conclusions involved in procurement decisions, impacts the ability to demonstrate that full and open competition occurred, or that noncompetitive procurement was appropriate.
Questioned Costs - None
Context - We tested a sample of eight procurement transactions and noted that the Organization did not maintain contemporaneously written documentation and conclusions as required by its procurement policy for the selected items.
Repeat Finding - No
Recommendation - We recommend Elwyn enforce its existing policy and procedures to ensure compliance with procurement requirements. Elwyn should provide targeted training to members of the Organization involved in procurement processes on its existing policy and procedures to ensure understanding of the Organization’s requirements for documentation of procurement methods. Additionally, Elwyn should ensure all procurement decisions are contemporaneously documented with the information necessary to conclude on appropriateness of the procurement with respect to the procurement policy and requirements.
Views of Responsible Officials - Management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the lapses in internal control.