2024 – 001: Procurement and Suspension and Debarment
Federal Agency: U.S. Department Education
Federal Program Name: Charter School Program
Assistance Listing Number: 84.282
Pass-Through Agency: Indiana Department of Education
Pass-Through Numbers: U282A200017, S282D200002
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or specific requirement: Per Charter School Program, Subtitle A, Chapter 2 Part 200,
Subpart D, section 200.318 of the Code of Federal Regulations requires Charter Schools to have a
written procurement policy that includes certain requirements as it relates to procuring good and
services using federal dollars. Additionally, 2 CFR 180.995 requires that the Charter School has a
written policy where the Charter School should perform a check to ensure vendors are not debarred.
Condition: During our testing, it was noted that PLA did not follow the written policy in place for
number of quotes and quote cost analysis. PLA did not comply with procurement policy it has in place
as the number of quotes for two (2) of five (5) procured purchases selected did not obtain the number
of quotes required by the policy.
During our testing, it was noted during that there is no written policy that requires PLA to verify that
vendors are suspended or debarred. We noted that PLA did not complete and document its verification
that vendors are not suspended or debarred vendors prior to being utilized. Four (4) of four (4) vendors
selected for testing were utilized during the audit period that did not have this documented. During audit
procedures, these vendors were checked and were not suspended or debarred.
Questioned costs: None
Context: PLA was unaware of the federal requirements for procurement and suspension and
debarment.
Cause: PLA’s procurement policy did not include all federal requirements.
Effect: Procured purchases could be completed not in accordance with PLA and federal requirements.
Vendors could be utilized for federal programs that are suspended and debarred.
Repeat finding: No.
Recommendation: We recommend that PLA review its procurement policy to ensure that a
suspension and debarment formal check and documentation be included to ensure that all federal
requirements are included in its written policies.
Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002: Special Tests and Provisions
Federal Agency: U.S Department Education
Federal Program Name: Education Stabilization Funds
Assistance Listing Number: 84.425D, 84.425U
Pass-Through Agency: Indiana Department of Education
Pass-Through Numbers: S425D210013, S425U210013
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
Material Weakness in Internal Control over Compliance
Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, "The non-Federal entity must: (a) Establish and
maintain effective internal control over the Federal award that provides reasonable assurance that the
non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller
General of the United States or the ‘Internal Control Integrated Framework’ issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). If governors, SEAs, and or
subrecipients propose to use ESF funds for construction they must also comply with applicable
requirements in 34 CFR section 76.600 and 34 CFR sections 75.600–617. Approved construction
projects must comply with all other applicable Uniform Guidance requirements, as well as the ED’s
regulations regarding construction, as applicable, at 34 CFR section 76.600. As is the case with all
construction contracts using laborers and mechanics financed by federal education funds, recipients
and subrecipients that use ESF funds for construction contracts over $2,000 must meet Davis-Bacon
prevailing wage requirements.
Condition: PLA did not verify compliance with prevailing wage requirements with subcontractors for
construction projects financed by federal education funds.
Questioned costs: $365,489.
Context: 1 of 1 construction projects financed by federal education funds were subject to prevailing
wage requirements.
Cause: PLA was not familiar with using federal education funds for construction costs and were not
aware of the prevailing wage requirements
Effect: Laborers and mechanics paid by subcontractors may have been paid below prevailing wage
rates.
Repeat Finding: Yes – 2023-002.
Recommendation: We recommend that for future construction contracts financed by federal education
funds PLA verify that subcontractors comply with prevailing wage requirements.
Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002: Special Tests and Provisions
Federal Agency: U.S Department Education
Federal Program Name: Education Stabilization Funds
Assistance Listing Number: 84.425D, 84.425U
Pass-Through Agency: Indiana Department of Education
Pass-Through Numbers: S425D210013, S425U210013
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
Material Weakness in Internal Control over Compliance
Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, "The non-Federal entity must: (a) Establish and
maintain effective internal control over the Federal award that provides reasonable assurance that the
non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller
General of the United States or the ‘Internal Control Integrated Framework’ issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). If governors, SEAs, and or
subrecipients propose to use ESF funds for construction they must also comply with applicable
requirements in 34 CFR section 76.600 and 34 CFR sections 75.600–617. Approved construction
projects must comply with all other applicable Uniform Guidance requirements, as well as the ED’s
regulations regarding construction, as applicable, at 34 CFR section 76.600. As is the case with all
construction contracts using laborers and mechanics financed by federal education funds, recipients
and subrecipients that use ESF funds for construction contracts over $2,000 must meet Davis-Bacon
prevailing wage requirements.
Condition: PLA did not verify compliance with prevailing wage requirements with subcontractors for
construction projects financed by federal education funds.
Questioned costs: $365,489.
Context: 1 of 1 construction projects financed by federal education funds were subject to prevailing
wage requirements.
Cause: PLA was not familiar with using federal education funds for construction costs and were not
aware of the prevailing wage requirements
Effect: Laborers and mechanics paid by subcontractors may have been paid below prevailing wage
rates.
Repeat Finding: Yes – 2023-002.
Recommendation: We recommend that for future construction contracts financed by federal education
funds PLA verify that subcontractors comply with prevailing wage requirements.
Views of responsible officials: There is no disagreement with the audit finding.
2024 – 001: Procurement and Suspension and Debarment
Federal Agency: U.S. Department Education
Federal Program Name: Charter School Program
Assistance Listing Number: 84.282
Pass-Through Agency: Indiana Department of Education
Pass-Through Numbers: U282A200017, S282D200002
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or specific requirement: Per Charter School Program, Subtitle A, Chapter 2 Part 200,
Subpart D, section 200.318 of the Code of Federal Regulations requires Charter Schools to have a
written procurement policy that includes certain requirements as it relates to procuring good and
services using federal dollars. Additionally, 2 CFR 180.995 requires that the Charter School has a
written policy where the Charter School should perform a check to ensure vendors are not debarred.
Condition: During our testing, it was noted that PLA did not follow the written policy in place for
number of quotes and quote cost analysis. PLA did not comply with procurement policy it has in place
as the number of quotes for two (2) of five (5) procured purchases selected did not obtain the number
of quotes required by the policy.
During our testing, it was noted during that there is no written policy that requires PLA to verify that
vendors are suspended or debarred. We noted that PLA did not complete and document its verification
that vendors are not suspended or debarred vendors prior to being utilized. Four (4) of four (4) vendors
selected for testing were utilized during the audit period that did not have this documented. During audit
procedures, these vendors were checked and were not suspended or debarred.
Questioned costs: None
Context: PLA was unaware of the federal requirements for procurement and suspension and
debarment.
Cause: PLA’s procurement policy did not include all federal requirements.
Effect: Procured purchases could be completed not in accordance with PLA and federal requirements.
Vendors could be utilized for federal programs that are suspended and debarred.
Repeat finding: No.
Recommendation: We recommend that PLA review its procurement policy to ensure that a
suspension and debarment formal check and documentation be included to ensure that all federal
requirements are included in its written policies.
Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002: Special Tests and Provisions
Federal Agency: U.S Department Education
Federal Program Name: Education Stabilization Funds
Assistance Listing Number: 84.425D, 84.425U
Pass-Through Agency: Indiana Department of Education
Pass-Through Numbers: S425D210013, S425U210013
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
Material Weakness in Internal Control over Compliance
Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, "The non-Federal entity must: (a) Establish and
maintain effective internal control over the Federal award that provides reasonable assurance that the
non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller
General of the United States or the ‘Internal Control Integrated Framework’ issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). If governors, SEAs, and or
subrecipients propose to use ESF funds for construction they must also comply with applicable
requirements in 34 CFR section 76.600 and 34 CFR sections 75.600–617. Approved construction
projects must comply with all other applicable Uniform Guidance requirements, as well as the ED’s
regulations regarding construction, as applicable, at 34 CFR section 76.600. As is the case with all
construction contracts using laborers and mechanics financed by federal education funds, recipients
and subrecipients that use ESF funds for construction contracts over $2,000 must meet Davis-Bacon
prevailing wage requirements.
Condition: PLA did not verify compliance with prevailing wage requirements with subcontractors for
construction projects financed by federal education funds.
Questioned costs: $365,489.
Context: 1 of 1 construction projects financed by federal education funds were subject to prevailing
wage requirements.
Cause: PLA was not familiar with using federal education funds for construction costs and were not
aware of the prevailing wage requirements
Effect: Laborers and mechanics paid by subcontractors may have been paid below prevailing wage
rates.
Repeat Finding: Yes – 2023-002.
Recommendation: We recommend that for future construction contracts financed by federal education
funds PLA verify that subcontractors comply with prevailing wage requirements.
Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002: Special Tests and Provisions
Federal Agency: U.S Department Education
Federal Program Name: Education Stabilization Funds
Assistance Listing Number: 84.425D, 84.425U
Pass-Through Agency: Indiana Department of Education
Pass-Through Numbers: S425D210013, S425U210013
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
Material Weakness in Internal Control over Compliance
Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, "The non-Federal entity must: (a) Establish and
maintain effective internal control over the Federal award that provides reasonable assurance that the
non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller
General of the United States or the ‘Internal Control Integrated Framework’ issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). If governors, SEAs, and or
subrecipients propose to use ESF funds for construction they must also comply with applicable
requirements in 34 CFR section 76.600 and 34 CFR sections 75.600–617. Approved construction
projects must comply with all other applicable Uniform Guidance requirements, as well as the ED’s
regulations regarding construction, as applicable, at 34 CFR section 76.600. As is the case with all
construction contracts using laborers and mechanics financed by federal education funds, recipients
and subrecipients that use ESF funds for construction contracts over $2,000 must meet Davis-Bacon
prevailing wage requirements.
Condition: PLA did not verify compliance with prevailing wage requirements with subcontractors for
construction projects financed by federal education funds.
Questioned costs: $365,489.
Context: 1 of 1 construction projects financed by federal education funds were subject to prevailing
wage requirements.
Cause: PLA was not familiar with using federal education funds for construction costs and were not
aware of the prevailing wage requirements
Effect: Laborers and mechanics paid by subcontractors may have been paid below prevailing wage
rates.
Repeat Finding: Yes – 2023-002.
Recommendation: We recommend that for future construction contracts financed by federal education
funds PLA verify that subcontractors comply with prevailing wage requirements.
Views of responsible officials: There is no disagreement with the audit finding.