2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section.
2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section.
2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements.
2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity.
Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member.
A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law.
Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds.
Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (including a cost or price analysis).
The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above.
Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding.
The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section.
2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section.
2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements.
2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity.
Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member.
A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law.
Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds.
Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (including a cost or price analysis).
The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above.
Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding.
The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section.
2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section.
2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements.
2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity.
Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member.
A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law.
Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds.
Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (including a cost or price analysis).
The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above.
Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding.
The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section.
2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section.
2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements.
2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity.
Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member.
A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law.
Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds.
Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (including a cost or price analysis).
The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above.
Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding.
The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section.
2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section.
2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements.
2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity.
Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member.
A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law.
Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds.
Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (including a cost or price analysis).
The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above.
Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding.
The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section.
2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section.
2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements.
2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity.
Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member.
A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law.
Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds.
Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (including a cost or price analysis).
The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above.
Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding.
The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section.
2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section.
2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements.
2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity.
Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member.
A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law.
Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds.
Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (including a cost or price analysis).
The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above.
Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding.
The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section.
2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section.
2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements.
2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity.
Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member.
A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law.
Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds.
Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (including a cost or price analysis).
The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above.
Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding.
The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.