Audit 393471

Criteria or Specifc Requirement: Per 2 CFR 200.303 - Internal Controls and the OMB Compliance Supplement: Special Education Cluster (IDEA), Procurement and Suspension and Debarment - the District is required to create, implement, and document an effective system of internal controls to certify that vendors utilized by the District are neither suspended nor debarred by the federal government. Condition: District personnel perform a search for all new vendors on SAM.gov's exclusion list to ensure that the vendor is neither suspended nor debarred from contracting with federal agencies; however, District personnel do not retain documentation that this search was performed. Questioned Costs: This condition resulted in no identified questioned costs. Context: District personnel are not documenting the procedures performed to ensure that vendors are neither suspended nor debarred by the federal governemnt. Effect: Is is possible for District personnel to not perform internal control procedures, as there is no way for management to determine if the procedure had been performed. Cause: The District's policies do not require that this procedure be documented. Recommendation: The District's policies should require that documentation is retained for all internal control procedures performed, including a search to verify that vendors are neither suspended nor debarred by the federal government. Management's Response: Management does not disagree with this response. Documentation will be maintained for this internal control in the future.