Audit 350401

Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. The District should have internal controls designed to ensure compliance with these provisions. Condition: The District does currently have procedures in place to verify vendors are not suspended or debarred prior to entering into a transaction with the entity. However, the District was not able to provide evidence that these procedures were performed for the covered transactions related to this grant. Questioned Costs: None. Context: The finding was noted in four of the four transactions tested. However, the transactions were not with entities that are suspended or debarred. Cause: The District had turnover in staff and was not able to locate any evidence that suspension and debarment was verified. Effect: There is a potential the District could contract with a debarred or suspended entity if the verification is not performed. Recommendation: We recommend the District perform suspension and debarment procedures on all vendors with which it plans to enter into a covered transaction and maintain the documentation for evidence of compliance. The District can do this by (a) checking sam.gov exclusions, or (b) collecting a certification from the entity, or (c) adding a clause or condition to the covered transaction with that entity. View of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. The District should have internal controls designed to ensure compliance with these provisions. Condition: The District does currently have procedures in place to verify vendors are not suspended or debarred prior to entering into a transaction with the entity. However, the District was not able to provide evidence that these procedures were performed for the covered transactions related to this grant. Questioned Costs: None. Context: The finding was noted in four of the four transactions tested. However, the transactions were not with entities that are suspended or debarred. Cause: The District had turnover in staff and was not able to locate any evidence that suspension and debarment was verified. Effect: There is a potential the District could contract with a debarred or suspended entity if the verification is not performed. Recommendation: We recommend the District perform suspension and debarment procedures on all vendors with which it plans to enter into a covered transaction and maintain the documentation for evidence of compliance. The District can do this by (a) checking sam.gov exclusions, or (b) collecting a certification from the entity, or (c) adding a clause or condition to the covered transaction with that entity. View of Responsible Officials: There is no disagreement with the audit finding.