CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with three (3) third-party vendors - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and McGraw-Hill Education for educational materials. The contract with Advanced Office Systems, Inc. was procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the copier procurement contract was competitively procured, such as a bid evaluation and public solicitation, 2) did not obtain the adequate number of price or rate quotations for the professional emotional support services, and 3) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. CAUSE: School District personnel directly responsible for the oversight and execution of the copier contract interpreted that the requirements specified by 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i), would be met through the cooperative purchasing, however the District appears to not have received and maintained all of the specific history of procurement documents internally, as referenced under the criteria section, to support this compliance. In addition, the District did not 1) maintain documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services, and 2) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, regarding maintaining records sufficient to detail the history of procurement for the copiers, and to document instances where there is a sole source provider such as would be required for the educational materials. In addition, the District did not comply with 24 PS 8.807.1 regarding maintaining documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services. QUESTIONED COST: $134,156 (Advanced Office Systems-$26,851) (Acorns to Oaks Consulting, LLC-$33,890) (McGraw-Hill Education-$73,415) RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, specifically Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i) of the Uniform Guidance. In addition, it is recommended that the District document its attempts to obtain an adequate number of price or rate quotations as specified by 24 PS 8.807.1 over the $10,000 expenditure threshold, as well as document instances whereby the District is using a sole source provider and accordingly competitive procurement procedures would not apply. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with three (3) third-party vendors - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and McGraw-Hill Education for educational materials. The contract with Advanced Office Systems, Inc. was procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the copier procurement contract was competitively procured, such as a bid evaluation and public solicitation, 2) did not obtain the adequate number of price or rate quotations for the professional emotional support services, and 3) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. CAUSE: School District personnel directly responsible for the oversight and execution of the copier contract interpreted that the requirements specified by 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i), would be met through the cooperative purchasing, however the District appears to not have received and maintained all of the specific history of procurement documents internally, as referenced under the criteria section, to support this compliance. In addition, the District did not 1) maintain documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services, and 2) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, regarding maintaining records sufficient to detail the history of procurement for the copiers, and to document instances where there is a sole source provider such as would be required for the educational materials. In addition, the District did not comply with 24 PS 8.807.1 regarding maintaining documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services. QUESTIONED COST: $134,156 (Advanced Office Systems-$26,851) (Acorns to Oaks Consulting, LLC-$33,890) (McGraw-Hill Education-$73,415) RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, specifically Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i) of the Uniform Guidance. In addition, it is recommended that the District document its attempts to obtain an adequate number of price or rate quotations as specified by 24 PS 8.807.1 over the $10,000 expenditure threshold, as well as document instances whereby the District is using a sole source provider and accordingly competitive procurement procedures would not apply. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with three (3) third-party vendors - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and McGraw-Hill Education for educational materials. The contract with Advanced Office Systems, Inc. was procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the copier procurement contract was competitively procured, such as a bid evaluation and public solicitation, 2) did not obtain the adequate number of price or rate quotations for the professional emotional support services, and 3) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. CAUSE: School District personnel directly responsible for the oversight and execution of the copier contract interpreted that the requirements specified by 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i), would be met through the cooperative purchasing, however the District appears to not have received and maintained all of the specific history of procurement documents internally, as referenced under the criteria section, to support this compliance. In addition, the District did not 1) maintain documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services, and 2) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, regarding maintaining records sufficient to detail the history of procurement for the copiers, and to document instances where there is a sole source provider such as would be required for the educational materials. In addition, the District did not comply with 24 PS 8.807.1 regarding maintaining documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services. QUESTIONED COST: $134,156 (Advanced Office Systems-$26,851) (Acorns to Oaks Consulting, LLC-$33,890) (McGraw-Hill Education-$73,415) RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, specifically Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i) of the Uniform Guidance. In addition, it is recommended that the District document its attempts to obtain an adequate number of price or rate quotations as specified by 24 PS 8.807.1 over the $10,000 expenditure threshold, as well as document instances whereby the District is using a sole source provider and accordingly competitive procurement procedures would not apply. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with three (3) third-party vendors - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and McGraw-Hill Education for educational materials. The contract with Advanced Office Systems, Inc. was procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the copier procurement contract was competitively procured, such as a bid evaluation and public solicitation, 2) did not obtain the adequate number of price or rate quotations for the professional emotional support services, and 3) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. CAUSE: School District personnel directly responsible for the oversight and execution of the copier contract interpreted that the requirements specified by 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i), would be met through the cooperative purchasing, however the District appears to not have received and maintained all of the specific history of procurement documents internally, as referenced under the criteria section, to support this compliance. In addition, the District did not 1) maintain documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services, and 2) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, regarding maintaining records sufficient to detail the history of procurement for the copiers, and to document instances where there is a sole source provider such as would be required for the educational materials. In addition, the District did not comply with 24 PS 8.807.1 regarding maintaining documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services. QUESTIONED COST: $134,156 (Advanced Office Systems-$26,851) (Acorns to Oaks Consulting, LLC-$33,890) (McGraw-Hill Education-$73,415) RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, specifically Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i) of the Uniform Guidance. In addition, it is recommended that the District document its attempts to obtain an adequate number of price or rate quotations as specified by 24 PS 8.807.1 over the $10,000 expenditure threshold, as well as document instances whereby the District is using a sole source provider and accordingly competitive procurement procedures would not apply. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with three (3) third-party vendors - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and McGraw-Hill Education for educational materials. The contract with Advanced Office Systems, Inc. was procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the copier procurement contract was competitively procured, such as a bid evaluation and public solicitation, 2) did not obtain the adequate number of price or rate quotations for the professional emotional support services, and 3) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. CAUSE: School District personnel directly responsible for the oversight and execution of the copier contract interpreted that the requirements specified by 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i), would be met through the cooperative purchasing, however the District appears to not have received and maintained all of the specific history of procurement documents internally, as referenced under the criteria section, to support this compliance. In addition, the District did not 1) maintain documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services, and 2) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, regarding maintaining records sufficient to detail the history of procurement for the copiers, and to document instances where there is a sole source provider such as would be required for the educational materials. In addition, the District did not comply with 24 PS 8.807.1 regarding maintaining documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services. QUESTIONED COST: $134,156 (Advanced Office Systems-$26,851) (Acorns to Oaks Consulting, LLC-$33,890) (McGraw-Hill Education-$73,415) RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, specifically Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i) of the Uniform Guidance. In addition, it is recommended that the District document its attempts to obtain an adequate number of price or rate quotations as specified by 24 PS 8.807.1 over the $10,000 expenditure threshold, as well as document instances whereby the District is using a sole source provider and accordingly competitive procurement procedures would not apply. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with three (3) third-party vendors - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and McGraw-Hill Education for educational materials. The contract with Advanced Office Systems, Inc. was procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the copier procurement contract was competitively procured, such as a bid evaluation and public solicitation, 2) did not obtain the adequate number of price or rate quotations for the professional emotional support services, and 3) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. CAUSE: School District personnel directly responsible for the oversight and execution of the copier contract interpreted that the requirements specified by 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i), would be met through the cooperative purchasing, however the District appears to not have received and maintained all of the specific history of procurement documents internally, as referenced under the criteria section, to support this compliance. In addition, the District did not 1) maintain documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services, and 2) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, regarding maintaining records sufficient to detail the history of procurement for the copiers, and to document instances where there is a sole source provider such as would be required for the educational materials. In addition, the District did not comply with 24 PS 8.807.1 regarding maintaining documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services. QUESTIONED COST: $134,156 (Advanced Office Systems-$26,851) (Acorns to Oaks Consulting, LLC-$33,890) (McGraw-Hill Education-$73,415) RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, specifically Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i) of the Uniform Guidance. In addition, it is recommended that the District document its attempts to obtain an adequate number of price or rate quotations as specified by 24 PS 8.807.1 over the $10,000 expenditure threshold, as well as document instances whereby the District is using a sole source provider and accordingly competitive procurement procedures would not apply. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with three (3) third-party vendors - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and McGraw-Hill Education for educational materials. The contract with Advanced Office Systems, Inc. was procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the copier procurement contract was competitively procured, such as a bid evaluation and public solicitation, 2) did not obtain the adequate number of price or rate quotations for the professional emotional support services, and 3) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. CAUSE: School District personnel directly responsible for the oversight and execution of the copier contract interpreted that the requirements specified by 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i), would be met through the cooperative purchasing, however the District appears to not have received and maintained all of the specific history of procurement documents internally, as referenced under the criteria section, to support this compliance. In addition, the District did not 1) maintain documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services, and 2) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, regarding maintaining records sufficient to detail the history of procurement for the copiers, and to document instances where there is a sole source provider such as would be required for the educational materials. In addition, the District did not comply with 24 PS 8.807.1 regarding maintaining documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services. QUESTIONED COST: $134,156 (Advanced Office Systems-$26,851) (Acorns to Oaks Consulting, LLC-$33,890) (McGraw-Hill Education-$73,415) RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, specifically Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i) of the Uniform Guidance. In addition, it is recommended that the District document its attempts to obtain an adequate number of price or rate quotations as specified by 24 PS 8.807.1 over the $10,000 expenditure threshold, as well as document instances whereby the District is using a sole source provider and accordingly competitive procurement procedures would not apply. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with two (2) third-party vendors - Eber HVAC, Inc. for the RTU Replacement Project and Advanced Office Systems, Inc. for the purchase of copier equipment, which constitute construction-related and capital purchases respectively which require prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for these expenditures.
CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval.
CAUSE: School District personnel did not review the PDE and Uniform Guidance requirements for capital purchases in advance of contracting for the RTU Replacement Project and copier equipment.
EFFECT: The Northern Cambria School District did not comply with the requirements of PDE and 2 CFR 200.439(b) of the Uniform Guidance regarding obtaining prior written approval for capital expenditures.
QUESTIONED COST: $1,501,951 (Eber HVAC-$1,475,100) (Advanced Office Systems-$26,851)
RECOMMENDATION: For all future capital expenditures utilizing federal grant funding, I am recommending that the School District properly complete the necessary PDE, or other awarding agency forms, necessary to receive prior written approval for capital expenditures in accordance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance regulations.
VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and has developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District contracted with three (3) third-party vendors - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and McGraw-Hill Education for educational materials. The contract with Advanced Office Systems, Inc. was procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the copier procurement contract was competitively procured, such as a bid evaluation and public solicitation, 2) did not obtain the adequate number of price or rate quotations for the professional emotional support services, and 3) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. CAUSE: School District personnel directly responsible for the oversight and execution of the copier contract interpreted that the requirements specified by 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i), would be met through the cooperative purchasing, however the District appears to not have received and maintained all of the specific history of procurement documents internally, as referenced under the criteria section, to support this compliance. In addition, the District did not 1) maintain documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services, and 2) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, regarding maintaining records sufficient to detail the history of procurement for the copiers, and to document instances where there is a sole source provider such as would be required for the educational materials. In addition, the District did not comply with 24 PS 8.807.1 regarding maintaining documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services. QUESTIONED COST: $134,156 (Advanced Office Systems-$26,851) (Acorns to Oaks Consulting, LLC-$33,890) (McGraw-Hill Education-$73,415) RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, specifically Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i) of the Uniform Guidance. In addition, it is recommended that the District document its attempts to obtain an adequate number of price or rate quotations as specified by 24 PS 8.807.1 over the $10,000 expenditure threshold, as well as document instances whereby the District is using a sole source provider and accordingly competitive procurement procedures would not apply. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: The Northern Cambria School District does not routinely perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District, it was noted that the contracts did not contain the required terms and conditions for non-federal entity contracts. CRITERIA: In accordance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements, contracts entered into by non-federal agencies must contain the applicable terms and conditions described in Appendix II to Subpart D. CAUSE: School District personnel inadvertently did not include the required terms and conditions in the selected contracts procured with federal funding. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.237 Subpart D regarding post federal award requirements for contracts entered into by non-federal agencies which require these contracts to contain the applicable terms and conditions described in Appendix II to Subpart D. QUESTIONED COST: $1,575,366 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (McGraw-Hill Education-$73,415). RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During a review of three (3) selected procurement contracts entered into by the Northern Cambria School District - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and Eber HVAC, Inc. for the RTU Replacement Project - it was noted that the School District was unable to provide purchase orders for these specific goods and services. CRITERIA: In accordance with Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs, costs must be adequately documented, and contain a purchase order approved by an administrator or supervisor submitted to the Business Manager and Superintendent. CAUSE: School District personnel erroneously assumed that in the selected instances tested, involving either a sole source provider or competitive bidding process, that a purchase order was not required. EFFECT: The Northern Cambria School District did not comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. QUESTIONED COST: $1,535,841 (Eber HVAC-$1,475,100), (Advanced Office Systems-$26,851), (Acorns to Oaks Consulting, LLC-$33,890). RECOMMENDATION: I am recommending that the management of the School District comply with the requirements of Section 2 CFR 200.403(g) of the Uniform Guidance, and the School District’s Board policy 626 for procurement – federal programs for ensuring that purchase orders are used. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).