Audit 318367

Procurement Process COVID-19 – Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Passed through the Oklahoma State Department of Education (Fund 723) Compliance Requirement: Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance; Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award the provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Effective May 14, 2022, the non-Federal entity must ensure that all applicable programs comply with section 70914 of the Build America, Buy America (BABA) Act, including through incorporation of a Buy America preference in the terms and conditions of each award with an infrastructure project. Condition: A vendor that was funded by the ELC program had not gone through the procurement process as required by applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Cause: The District has previously funded the vendor using state and local funds rather than federal funds for the past several years. The vendor’s service was identified that the use of the funds was an allowable activity and cost, but the vendor had not gone through the required procurement process for federally funded programs. Effect: The District is out of compliance with federal requirements regarding procurement and could be contracting with vendors that are not the most practical for the District. Context/Sampling: Both of the two vendors that met this scope in this program was tested so no sampling was necessary. Repeat Finding From Prior Year: No Questioned costs: Funds spent with this vendor in this program were $486,260. Recommendation: Control procedures should be implemented to ensure that all vendors that are paid with federal funds following the required procurement regulations and ensure federal updates are regularly made to ensure continued compliance with procurement requirements. Views of Responsible Officials: The District understands the importance of complying with federal procurement requirements and will ensure all staff involved with federal funds are informed of the procurement rules with the addition of the federal compliance procedures to our Fiscal Management Policy.

Procurement Process COVID-19 – Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Passed through the Oklahoma State Department of Education (Fund 723) Compliance Requirement: Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance; Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award the provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Effective May 14, 2022, the non-Federal entity must ensure that all applicable programs comply with section 70914 of the Build America, Buy America (BABA) Act, including through incorporation of a Buy America preference in the terms and conditions of each award with an infrastructure project. Condition: A vendor that was funded by the ELC program had not gone through the procurement process as required by applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Cause: The District has previously funded the vendor using state and local funds rather than federal funds for the past several years. The vendor’s service was identified that the use of the funds was an allowable activity and cost, but the vendor had not gone through the required procurement process for federally funded programs. Effect: The District is out of compliance with federal requirements regarding procurement and could be contracting with vendors that are not the most practical for the District. Context/Sampling: Both of the two vendors that met this scope in this program was tested so no sampling was necessary. Repeat Finding From Prior Year: No Questioned costs: Funds spent with this vendor in this program were $486,260. Recommendation: Control procedures should be implemented to ensure that all vendors that are paid with federal funds following the required procurement regulations and ensure federal updates are regularly made to ensure continued compliance with procurement requirements. Views of Responsible Officials: The District understands the importance of complying with federal procurement requirements and will ensure all staff involved with federal funds are informed of the procurement rules with the addition of the federal compliance procedures to our Fiscal Management Policy.