Audit 344092

2022-004 – Procurement, Suspension, and Debarment Federal Program Information Funding Agency: US Department of Education Title: Special Education Cluster AL Number: 84.027; 84.173 Criteria Non-federal entities other than 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. Furthermore, Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000. Condition Upper Valley Special Education District does not have a written procurement policy in place that follows Uniform Guidance. In addition, the District is not reviewing applicable vendors for suspension and debarment. Questioned Costs None. Context During inquiry and testing we noted that UVSE did not have a procurement policy in place that follows Uniform Guidance and that they do not ensure vendors are not suspended or debarred from receiving federal funds. Effect Upper Valley Special Education District is not in compliance with Uniform Guidance procurement, suspension, and procurement requirements. Also, the District has an increased risk of entering into a covered transaction with a vendor who is suspended or debarred from receiving federal funds. Cause Management oversight. Recommendation The District’s should create and implement a procurement policy that follows federal requirements. The District should also create policies and procedures to ensure they do not enter into a covered transaction with a vendor who is suspended or debarred from receiving federal funds. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

2022-004 – Procurement, Suspension, and Debarment Federal Program Information Funding Agency: US Department of Education Title: Special Education Cluster AL Number: 84.027; 84.173 Criteria Non-federal entities other than 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. Furthermore, Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000. Condition Upper Valley Special Education District does not have a written procurement policy in place that follows Uniform Guidance. In addition, the District is not reviewing applicable vendors for suspension and debarment. Questioned Costs None. Context During inquiry and testing we noted that UVSE did not have a procurement policy in place that follows Uniform Guidance and that they do not ensure vendors are not suspended or debarred from receiving federal funds. Effect Upper Valley Special Education District is not in compliance with Uniform Guidance procurement, suspension, and procurement requirements. Also, the District has an increased risk of entering into a covered transaction with a vendor who is suspended or debarred from receiving federal funds. Cause Management oversight. Recommendation The District’s should create and implement a procurement policy that follows federal requirements. The District should also create policies and procedures to ensure they do not enter into a covered transaction with a vendor who is suspended or debarred from receiving federal funds. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

2022-004 – Procurement, Suspension, and Debarment Federal Program Information Funding Agency: US Department of Education Title: Special Education Cluster AL Number: 84.027; 84.173 Criteria Non-federal entities other than 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. Furthermore, Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000. Condition Upper Valley Special Education District does not have a written procurement policy in place that follows Uniform Guidance. In addition, the District is not reviewing applicable vendors for suspension and debarment. Questioned Costs None. Context During inquiry and testing we noted that UVSE did not have a procurement policy in place that follows Uniform Guidance and that they do not ensure vendors are not suspended or debarred from receiving federal funds. Effect Upper Valley Special Education District is not in compliance with Uniform Guidance procurement, suspension, and procurement requirements. Also, the District has an increased risk of entering into a covered transaction with a vendor who is suspended or debarred from receiving federal funds. Cause Management oversight. Recommendation The District’s should create and implement a procurement policy that follows federal requirements. The District should also create policies and procedures to ensure they do not enter into a covered transaction with a vendor who is suspended or debarred from receiving federal funds. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

2022-004 – Procurement, Suspension, and Debarment Federal Program Information Funding Agency: US Department of Education Title: Special Education Cluster AL Number: 84.027; 84.173 Criteria Non-federal entities other than 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. Furthermore, Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000. Condition Upper Valley Special Education District does not have a written procurement policy in place that follows Uniform Guidance. In addition, the District is not reviewing applicable vendors for suspension and debarment. Questioned Costs None. Context During inquiry and testing we noted that UVSE did not have a procurement policy in place that follows Uniform Guidance and that they do not ensure vendors are not suspended or debarred from receiving federal funds. Effect Upper Valley Special Education District is not in compliance with Uniform Guidance procurement, suspension, and procurement requirements. Also, the District has an increased risk of entering into a covered transaction with a vendor who is suspended or debarred from receiving federal funds. Cause Management oversight. Recommendation The District’s should create and implement a procurement policy that follows federal requirements. The District should also create policies and procedures to ensure they do not enter into a covered transaction with a vendor who is suspended or debarred from receiving federal funds. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.