FAC Explorer

Audit 301534

FY End
2023-06-30
Total Expended
$1.09M
Findings
2
Programs
10
Organization: Western Beaver County School District (PA)
Year: 2023 Accepted: 2024-04-01
Auditor: Mark C Turnley CPA

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
390816 2023-001 Material Weakness - I
967258 2023-001 Material Weakness - I

Programs

ALN Program Spent Major Findings
84.010 Title I Grants to Local Educational Agencies $129,302 - 0
84.027 Special Education_grants to States $115,869 Yes 0
10.553 School Breakfast Program $72,292 - 0
10.555 National School Lunch Program $46,352 - 0
84.367 Improving Teacher Quality State Grants $19,080 - 0
84.424 Student Support and Academic Enrichment Program $10,307 - 0
84.425 Education Stabilization Fund $3,642 Yes 0
93.778 Medical Assistance Program $2,758 - 0
84.173 Special Education_preschool Grants $1,554 Yes 0
10.649 Pandemic Ebt Administrative Costs $628 - 0

Contacts

Name Title Type
RZZEKH2HGX13 Rob Postupac Auditee
7246439310 Kim Turnley Auditor
No contacts on file

Notes to SEFA

Title: NOTE 1 – BASIS OF PRESENTATION Accounting Policies: BASIS OF ACCOUNTING Expenditures reported on the Schedule are presented using the accrual method of accounting. Under this method, grant revenue is recognized to the extent expenditures are incurred. Expenditures are recognized when the liability for the expenditure is incurred rather than when the disbursement is actually made. The federal expenditures are recognized, as applicable, under the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or limited to reimbursement. De Minimis Rate Used: N Rate Explanation: The School District utilizes the indirect cost rate as prescribed under the terms of the grant agreement if applicable. The accompanying schedule of expenditures of federal awards (the ‘Schedule’) includes the federal grant activity administered by the Western Beaver County Area School District for the year ended June 30, 2023. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Grant Guidance – UGG). Because the Schedule presents only a selected portion of the operations of the School District, it is not intended to and does not present the financial position or changes in net position of the Western Beaver County Area School District.
Title: NOTE 3 - RELATIONSHIP TO FINANCIAL STATEMENTS Accounting Policies: BASIS OF ACCOUNTING Expenditures reported on the Schedule are presented using the accrual method of accounting. Under this method, grant revenue is recognized to the extent expenditures are incurred. Expenditures are recognized when the liability for the expenditure is incurred rather than when the disbursement is actually made. The federal expenditures are recognized, as applicable, under the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or limited to reimbursement. De Minimis Rate Used: N Rate Explanation: The School District utilizes the indirect cost rate as prescribed under the terms of the grant agreement if applicable. Federal financial award revenues are included in the financial statements as ‘local source’ and 'federal source' revenues.
Title: NOTE 4 – RECEIVABLES AND UNEARNED REVENUE Accounting Policies: BASIS OF ACCOUNTING Expenditures reported on the Schedule are presented using the accrual method of accounting. Under this method, grant revenue is recognized to the extent expenditures are incurred. Expenditures are recognized when the liability for the expenditure is incurred rather than when the disbursement is actually made. The federal expenditures are recognized, as applicable, under the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or limited to reimbursement. De Minimis Rate Used: N Rate Explanation: The School District utilizes the indirect cost rate as prescribed under the terms of the grant agreement if applicable. Federal grants receivable is included as part of 'due from other governments' in Exhibit A and Exhibit C as referenced in Note 4 to the Financial Statements. Unearned federal grant revenue, if any, is included as part of 'unearned revenue' in Exhibit A and Exhibit C and is referenced in Note 5 to the Financial Statements.
Title: NOTE 5 - NON-CASH ASSISTANCE Accounting Policies: BASIS OF ACCOUNTING Expenditures reported on the Schedule are presented using the accrual method of accounting. Under this method, grant revenue is recognized to the extent expenditures are incurred. Expenditures are recognized when the liability for the expenditure is incurred rather than when the disbursement is actually made. The federal expenditures are recognized, as applicable, under the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or limited to reimbursement. De Minimis Rate Used: N Rate Explanation: The School District utilizes the indirect cost rate as prescribed under the terms of the grant agreement if applicable. The Western Beaver County Area School District received donated commodities from the Department of Agriculture in connection with its food service program. The amount of non-cash assistance expended in the accompanying schedule of expenditures of federal awards reflects the fair market value of the commodities used during the 2022-2023 fiscal year.

Finding Details

Finding 2023-001
CONDITION: The Western Beaver County School District contracted with two (2) third-party vendors – CCL Technologies and AVI-SPL LLC for the purchase of technology equipment. The contracts were procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the technology procurement contracts were competitively procured, such as a bid evaluation and public solicitation and 2) did not obtain the adequate number of price or rate quotations. 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 technology contracts 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 maintain documentation to substantiate that an adequate number of price quotations were solicited. EFFECT: The Western Beaver County 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 technology equipment. 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 for the technology equipment. QUESTIONED COST: $152,796 (CCL Technologies), $121,290 (AVI-SPL LLC) 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. 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).
Finding 2023-001
CONDITION: The Western Beaver County School District contracted with two (2) third-party vendors – CCL Technologies and AVI-SPL LLC for the purchase of technology equipment. The contracts were procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the technology procurement contracts were competitively procured, such as a bid evaluation and public solicitation and 2) did not obtain the adequate number of price or rate quotations. 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 technology contracts 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 maintain documentation to substantiate that an adequate number of price quotations were solicited. EFFECT: The Western Beaver County 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 technology equipment. 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 for the technology equipment. QUESTIONED COST: $152,796 (CCL Technologies), $121,290 (AVI-SPL LLC) 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. 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).