FA 2024-001 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S Department of Education
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 84.027 – Special Education Grants to State
84.173 – Special Education Preschool Grants
Federal Award Numbers: H027A220073 (Year 2023), H027A230073 (Year 2024)
H173A220081 (Year 2023), H173A230081 (Year 2024)
Questioned Costs: None Identified
Description:
A review of expenditures charged to the Special Education Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement and suspension and debarment procedures were followed.
Background:
The Special Education Cluster (SEC), which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). SEC funding is available to ensure that all children with disabilities have available to them, a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities.
SEC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to local education agencies (LEAs) and overseeing the expenditure of funds by LEAs. SEC funds totaling $404,087.80 were expended and reported on the Marion County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures, which reflects applicable State and local laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources…”
Furthermore Title 2 CFR Section 180.300 state in part that the non-federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of eight procurement transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for one small purchase expenditure reviewed. While auditors were able to perform procedures to determine that the expenditure ultimately qualified as a sole source purchase, appropriate documentation was not maintained on file to support the rationale to limit competition.
Additionally, a sample of two covered transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment requirements were met. While auditors were able to determine that the vendor associated with these transactions was not suspended, debarred, or otherwise excluded, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction as is required by the School District’s internal policies and procedures.
Cause:
In discussing the deficiencies with management, they stated that these are isolated incidents where the vendors were considered sole source because of the specialized services they provided, and as result, the procedures were not followed due to oversight.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to appropriately implement procedures to address procurement and suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures in the future.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment procedures are followed, and appropriate documentation is obtained and retained on-file. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding
FA 2024-001 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S Department of Education
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 84.027 – Special Education Grants to State
84.173 – Special Education Preschool Grants
Federal Award Numbers: H027A220073 (Year 2023), H027A230073 (Year 2024)
H173A220081 (Year 2023), H173A230081 (Year 2024)
Questioned Costs: None Identified
Description:
A review of expenditures charged to the Special Education Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement and suspension and debarment procedures were followed.
Background:
The Special Education Cluster (SEC), which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). SEC funding is available to ensure that all children with disabilities have available to them, a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities.
SEC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to local education agencies (LEAs) and overseeing the expenditure of funds by LEAs. SEC funds totaling $404,087.80 were expended and reported on the Marion County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures, which reflects applicable State and local laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources…”
Furthermore Title 2 CFR Section 180.300 state in part that the non-federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of eight procurement transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for one small purchase expenditure reviewed. While auditors were able to perform procedures to determine that the expenditure ultimately qualified as a sole source purchase, appropriate documentation was not maintained on file to support the rationale to limit competition.
Additionally, a sample of two covered transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment requirements were met. While auditors were able to determine that the vendor associated with these transactions was not suspended, debarred, or otherwise excluded, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction as is required by the School District’s internal policies and procedures.
Cause:
In discussing the deficiencies with management, they stated that these are isolated incidents where the vendors were considered sole source because of the specialized services they provided, and as result, the procedures were not followed due to oversight.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to appropriately implement procedures to address procurement and suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures in the future.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment procedures are followed, and appropriate documentation is obtained and retained on-file. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding
FA 2024-001 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S Department of Education
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 84.027 – Special Education Grants to State
84.173 – Special Education Preschool Grants
Federal Award Numbers: H027A220073 (Year 2023), H027A230073 (Year 2024)
H173A220081 (Year 2023), H173A230081 (Year 2024)
Questioned Costs: None Identified
Description:
A review of expenditures charged to the Special Education Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement and suspension and debarment procedures were followed.
Background:
The Special Education Cluster (SEC), which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). SEC funding is available to ensure that all children with disabilities have available to them, a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities.
SEC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to local education agencies (LEAs) and overseeing the expenditure of funds by LEAs. SEC funds totaling $404,087.80 were expended and reported on the Marion County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures, which reflects applicable State and local laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources…”
Furthermore Title 2 CFR Section 180.300 state in part that the non-federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of eight procurement transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for one small purchase expenditure reviewed. While auditors were able to perform procedures to determine that the expenditure ultimately qualified as a sole source purchase, appropriate documentation was not maintained on file to support the rationale to limit competition.
Additionally, a sample of two covered transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment requirements were met. While auditors were able to determine that the vendor associated with these transactions was not suspended, debarred, or otherwise excluded, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction as is required by the School District’s internal policies and procedures.
Cause:
In discussing the deficiencies with management, they stated that these are isolated incidents where the vendors were considered sole source because of the specialized services they provided, and as result, the procedures were not followed due to oversight.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to appropriately implement procedures to address procurement and suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures in the future.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment procedures are followed, and appropriate documentation is obtained and retained on-file. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding
FA 2024-001 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S Department of Education
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 84.027 – Special Education Grants to State
84.173 – Special Education Preschool Grants
Federal Award Numbers: H027A220073 (Year 2023), H027A230073 (Year 2024)
H173A220081 (Year 2023), H173A230081 (Year 2024)
Questioned Costs: None Identified
Description:
A review of expenditures charged to the Special Education Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement and suspension and debarment procedures were followed.
Background:
The Special Education Cluster (SEC), which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). SEC funding is available to ensure that all children with disabilities have available to them, a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities.
SEC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to local education agencies (LEAs) and overseeing the expenditure of funds by LEAs. SEC funds totaling $404,087.80 were expended and reported on the Marion County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures, which reflects applicable State and local laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources…”
Furthermore Title 2 CFR Section 180.300 state in part that the non-federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of eight procurement transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for one small purchase expenditure reviewed. While auditors were able to perform procedures to determine that the expenditure ultimately qualified as a sole source purchase, appropriate documentation was not maintained on file to support the rationale to limit competition.
Additionally, a sample of two covered transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment requirements were met. While auditors were able to determine that the vendor associated with these transactions was not suspended, debarred, or otherwise excluded, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction as is required by the School District’s internal policies and procedures.
Cause:
In discussing the deficiencies with management, they stated that these are isolated incidents where the vendors were considered sole source because of the specialized services they provided, and as result, the procedures were not followed due to oversight.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to appropriately implement procedures to address procurement and suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures in the future.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment procedures are followed, and appropriate documentation is obtained and retained on-file. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding
FA 2024-001 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S Department of Education
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 84.027 – Special Education Grants to State
84.173 – Special Education Preschool Grants
Federal Award Numbers: H027A220073 (Year 2023), H027A230073 (Year 2024)
H173A220081 (Year 2023), H173A230081 (Year 2024)
Questioned Costs: None Identified
Description:
A review of expenditures charged to the Special Education Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement and suspension and debarment procedures were followed.
Background:
The Special Education Cluster (SEC), which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). SEC funding is available to ensure that all children with disabilities have available to them, a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities.
SEC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to local education agencies (LEAs) and overseeing the expenditure of funds by LEAs. SEC funds totaling $404,087.80 were expended and reported on the Marion County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures, which reflects applicable State and local laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources…”
Furthermore Title 2 CFR Section 180.300 state in part that the non-federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of eight procurement transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for one small purchase expenditure reviewed. While auditors were able to perform procedures to determine that the expenditure ultimately qualified as a sole source purchase, appropriate documentation was not maintained on file to support the rationale to limit competition.
Additionally, a sample of two covered transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment requirements were met. While auditors were able to determine that the vendor associated with these transactions was not suspended, debarred, or otherwise excluded, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction as is required by the School District’s internal policies and procedures.
Cause:
In discussing the deficiencies with management, they stated that these are isolated incidents where the vendors were considered sole source because of the specialized services they provided, and as result, the procedures were not followed due to oversight.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to appropriately implement procedures to address procurement and suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures in the future.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment procedures are followed, and appropriate documentation is obtained and retained on-file. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding
FA 2024-001 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S Department of Education
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 84.027 – Special Education Grants to State
84.173 – Special Education Preschool Grants
Federal Award Numbers: H027A220073 (Year 2023), H027A230073 (Year 2024)
H173A220081 (Year 2023), H173A230081 (Year 2024)
Questioned Costs: None Identified
Description:
A review of expenditures charged to the Special Education Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement and suspension and debarment procedures were followed.
Background:
The Special Education Cluster (SEC), which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). SEC funding is available to ensure that all children with disabilities have available to them, a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities.
SEC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to local education agencies (LEAs) and overseeing the expenditure of funds by LEAs. SEC funds totaling $404,087.80 were expended and reported on the Marion County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures, which reflects applicable State and local laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources…”
Furthermore Title 2 CFR Section 180.300 state in part that the non-federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of eight procurement transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for one small purchase expenditure reviewed. While auditors were able to perform procedures to determine that the expenditure ultimately qualified as a sole source purchase, appropriate documentation was not maintained on file to support the rationale to limit competition.
Additionally, a sample of two covered transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment requirements were met. While auditors were able to determine that the vendor associated with these transactions was not suspended, debarred, or otherwise excluded, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction as is required by the School District’s internal policies and procedures.
Cause:
In discussing the deficiencies with management, they stated that these are isolated incidents where the vendors were considered sole source because of the specialized services they provided, and as result, the procedures were not followed due to oversight.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to appropriately implement procedures to address procurement and suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures in the future.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment procedures are followed, and appropriate documentation is obtained and retained on-file. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding
FA 2024-001 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S Department of Education
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 84.027 – Special Education Grants to State
84.173 – Special Education Preschool Grants
Federal Award Numbers: H027A220073 (Year 2023), H027A230073 (Year 2024)
H173A220081 (Year 2023), H173A230081 (Year 2024)
Questioned Costs: None Identified
Description:
A review of expenditures charged to the Special Education Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement and suspension and debarment procedures were followed.
Background:
The Special Education Cluster (SEC), which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). SEC funding is available to ensure that all children with disabilities have available to them, a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities.
SEC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to local education agencies (LEAs) and overseeing the expenditure of funds by LEAs. SEC funds totaling $404,087.80 were expended and reported on the Marion County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures, which reflects applicable State and local laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources…”
Furthermore Title 2 CFR Section 180.300 state in part that the non-federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of eight procurement transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for one small purchase expenditure reviewed. While auditors were able to perform procedures to determine that the expenditure ultimately qualified as a sole source purchase, appropriate documentation was not maintained on file to support the rationale to limit competition.
Additionally, a sample of two covered transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment requirements were met. While auditors were able to determine that the vendor associated with these transactions was not suspended, debarred, or otherwise excluded, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction as is required by the School District’s internal policies and procedures.
Cause:
In discussing the deficiencies with management, they stated that these are isolated incidents where the vendors were considered sole source because of the specialized services they provided, and as result, the procedures were not followed due to oversight.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to appropriately implement procedures to address procurement and suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures in the future.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment procedures are followed, and appropriate documentation is obtained and retained on-file. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding
FA 2024-001 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S Department of Education
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 84.027 – Special Education Grants to State
84.173 – Special Education Preschool Grants
Federal Award Numbers: H027A220073 (Year 2023), H027A230073 (Year 2024)
H173A220081 (Year 2023), H173A230081 (Year 2024)
Questioned Costs: None Identified
Description:
A review of expenditures charged to the Special Education Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement and suspension and debarment procedures were followed.
Background:
The Special Education Cluster (SEC), which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). SEC funding is available to ensure that all children with disabilities have available to them, a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities.
SEC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to local education agencies (LEAs) and overseeing the expenditure of funds by LEAs. SEC funds totaling $404,087.80 were expended and reported on the Marion County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures, which reflects applicable State and local laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources…”
Furthermore Title 2 CFR Section 180.300 state in part that the non-federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of eight procurement transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for one small purchase expenditure reviewed. While auditors were able to perform procedures to determine that the expenditure ultimately qualified as a sole source purchase, appropriate documentation was not maintained on file to support the rationale to limit competition.
Additionally, a sample of two covered transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment requirements were met. While auditors were able to determine that the vendor associated with these transactions was not suspended, debarred, or otherwise excluded, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction as is required by the School District’s internal policies and procedures.
Cause:
In discussing the deficiencies with management, they stated that these are isolated incidents where the vendors were considered sole source because of the specialized services they provided, and as result, the procedures were not followed due to oversight.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to appropriately implement procedures to address procurement and suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures in the future.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment procedures are followed, and appropriate documentation is obtained and retained on-file. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding