Audit 31107

Program: CFDA 84.282 ? Charter Schools Sponsor Award Number: 0089-21-1044 Sponsor Agency: New York State Education Department Criteria: Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing executive orders and 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Citation: 2 CFR 200.213 Condition: ICS has a formal policy in place to evaluate contracts with vendors that are considered covered under 2 CFR 180.200 to ensure that the recipients of federal funding was not suspended or debarred, however, this policy was not followed, and documentation to support management?s determination was not maintained for all applicable vendors. Cause: ICS did not follow the suspension and debarment policies in place. Effect: There is a risk that vendors who are suspended or debarred will receive federal funds through payment on their contract with ICS. Questioned Costs: None. There were no instances of non-compliance noted. Context: Management did not have formal documentation for 7 of 32 applicable vendors regarding whether procedures were performed to determine if the vendors selected have been suspended or debarred. Repeat Finding: Yes Recommendation: We recommend that management follows their written procedures and maintain supporting documentation for evaluating vendors to ensure they have not been suspended or debarred. Views of Responsible Officials: See Corrective Action Plan attached.

Program: CFDA 84.282 ? Charter Schools Sponsor Award Number: 0089-21-1044 Sponsor Agency: New York State Education Department Criteria: Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing executive orders and 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Citation: 2 CFR 200.213 Condition: ICS has a formal policy in place to evaluate contracts with vendors that are considered covered under 2 CFR 180.200 to ensure that the recipients of federal funding was not suspended or debarred, however, this policy was not followed, and documentation to support management?s determination was not maintained for all applicable vendors. Cause: ICS did not follow the suspension and debarment policies in place. Effect: There is a risk that vendors who are suspended or debarred will receive federal funds through payment on their contract with ICS. Questioned Costs: None. There were no instances of non-compliance noted. Context: Management did not have formal documentation for 7 of 32 applicable vendors regarding whether procedures were performed to determine if the vendors selected have been suspended or debarred. Repeat Finding: Yes Recommendation: We recommend that management follows their written procedures and maintain supporting documentation for evaluating vendors to ensure they have not been suspended or debarred. Views of Responsible Officials: See Corrective Action Plan attached.