Audit 36667

Reference Number: 2022-001 ? Procurement, Suspension, and Debarment Federal Agency: Federal Communication Commission Federal Program: Emergency Connectivity Fund Program ? ALN 32.009 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Criteria: Federal grant recipients are prohibited from contracting with parties suspended or debarred from doing business with the federal government. Federal regulations require that grant recipients ensure vendors are not suspended or debarred from doing business with the federal government. This verification may be accomplished by checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA), collection of a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Statement of Condition: The School District contracted the purchase of mobile routers, modems, and antennas in which the vendors were not verified to not be suspended or debarred from receiving federal funds. During testing, it was found that applicable vendors were not listed as suspended or debarred. Statement of Cause: While internal control policies are in place to address the procurement, suspension, and debarment requirements, these policies were not followed due to the fact the School District was unaware that the grant was federally funded until after the equipment was purchased. Possible Asserted Effect: The School District could have purchased goods or services from suspended or debarred vendors that are not eligible to receive federal funds. Questioned Costs: None Context: The School District had two transactions that were applied to the Emergency Connectivity Fund Program during the fiscal year to the same vendor. Therefore, we tested all federal expenditures that would have required the School District to follow the procurement, suspension, and debarment requirements. Recommendation: The School District should ensure whether all funding sources, specifically grants, are federally funded and follow the related procurement, suspension, and debarment internal control policies previously established. Views of responsible officials and planned corrective action: The School District will require all grants to be submitted to the Business Office with applications and award letters. In addition, a form will be designed that will be attached to the application and award letter along with a request for a funding source to track revenues and expenditures.

Reference Number: 2022-001 ? Procurement, Suspension, and Debarment Federal Agency: Federal Communication Commission Federal Program: Emergency Connectivity Fund Program ? ALN 32.009 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Criteria: Federal grant recipients are prohibited from contracting with parties suspended or debarred from doing business with the federal government. Federal regulations require that grant recipients ensure vendors are not suspended or debarred from doing business with the federal government. This verification may be accomplished by checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA), collection of a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Statement of Condition: The School District contracted the purchase of mobile routers, modems, and antennas in which the vendors were not verified to not be suspended or debarred from receiving federal funds. During testing, it was found that applicable vendors were not listed as suspended or debarred. Statement of Cause: While internal control policies are in place to address the procurement, suspension, and debarment requirements, these policies were not followed due to the fact the School District was unaware that the grant was federally funded until after the equipment was purchased. Possible Asserted Effect: The School District could have purchased goods or services from suspended or debarred vendors that are not eligible to receive federal funds. Questioned Costs: None Context: The School District had two transactions that were applied to the Emergency Connectivity Fund Program during the fiscal year to the same vendor. Therefore, we tested all federal expenditures that would have required the School District to follow the procurement, suspension, and debarment requirements. Recommendation: The School District should ensure whether all funding sources, specifically grants, are federally funded and follow the related procurement, suspension, and debarment internal control policies previously established. Views of responsible officials and planned corrective action: The School District will require all grants to be submitted to the Business Office with applications and award letters. In addition, a form will be designed that will be attached to the application and award letter along with a request for a funding source to track revenues and expenditures.