Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-004 ? Procurement. (ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER III, ALN 84.010 Title I grants to local educational agencies and ALN 84.367 Supporting effective instruction state grants) CRITERIA: Appendix II to 2 CFR 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires that all contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity, including the manner by which it will be affected and the basis for settlement. CONDITION: Our testing of nonpayroll expenditures showed purchase orders issued for contractual services for educational consulting services. Written contracts containing language that addresses termination for cause and for convenience by the school district, including the manner by which it will be affected and the basis for settlement, were not entered into. The district considered the purchase orders to be contracts for the services; however, there was no wording on the purchase orders that addressed termination for cause or convenience. CAUSE: The school district did not realize that written contract elements were required for contracts in excess of $10,000 and further did not realize that specific termination language should be included in the written contracts. EFFECT: The district did not comply with the provisions outlined in Appendix II to 2 CFR 200. QUESTIONED COSTS: None RECOMMENDATION: The district should familiarize itself with the requirements of Appendix II to Part 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-006. Equipment Management. (ALN 84.010 Title I grants to local educational agencies; ALN 84.424 Student support and academic enrichment grants, and ALN 84.425U ARP ESSER III) CRITERIA: 2 CFR 200.313(d)(1) requires for federal grants that property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, the acquisition date, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Since the State of Mississippi has more stringent criteria for tracking equipment inventory, the district must follow the following guidelines for equipment purchased with federal funds. Code Section 37-17-6(18) requires that the State Board of Education, acting through the Commission on School Accreditation, shall require each school district to comply with standards established by the State Department of Audit for the verification of fixed assets and the auditing of fixed assets records as a minimum requirement for accreditation. The State Department of Audit has issued an asset management manual to be used as a standard for verification of fixed assets. The school board has policies and procedures outlining the control and verification of fixed assets within the school district. As part of the asset management manual and local board policy, the district is charged with tracking assets meeting certain thresholds and performing physical verification of those assets at least annually. CONDITION: During our testing, we noted various pieces of equipment purchased with grant dollars totaling $92,555.68 that had not been added to the district?s subsidiary equipment records at the time of audit fieldwork. None of the purchased equipment met the threshold for depreciation; however, all the equipment met the threshold and criteria for tagging and inclusion in the subsidiary equipment records. These purchases were spread over three different federal grants as follows: ALN 84.010 Title I grants to local education agencies - $14,491.39 ALN 84.424 Student support and academic enrichments grants - $40,872.29 ALN 84.425U ARP ESSER III - $37,192.00 The school district stated that even though the equipment had not been added to the subsidiary records at the time of audit fieldwork, all equipment had been properly tagged. A physical inventory performed at the end of the 2021-2022 year would not have included all assets purchased during the 2021-2022 year because of the assets that had not been added to the inventory records at the time of purchase and tagging, therefore a year end inventory would have been incomplete. Our testing of the physical existence of selected fixed asset items revealed three (3) instances where assets appropriately included in the inventory records were not found at the time of testing. The three (3) assets not located were two (2) chromebooks and one (1) ipad with an original combined purchase price of $1,249.43. The assets were purchased from the following federal grant: ALN 84.425U ARP ESSER III - $1,249.43 CAUSE: The school district personnel failed to follow established policies for the recording of purchased equipment meeting the criteria for inclusion in equipment subsidiary records to the subsidiary records. EFFECT: The effect is a breakdown in controls surrounding the safeguarding of equipment purchased with federal dollars. Equipment purchased for use in the federal program could be used for purposes not related to the program or converted to personal use. QUESTIONED COSTS: None RECOMMENDATION: The district should follow established policies and procedures outlining the safeguarding of equipment purchased with federal grant dollars. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-004 ? Procurement. (ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER III, ALN 84.010 Title I grants to local educational agencies and ALN 84.367 Supporting effective instruction state grants) CRITERIA: Appendix II to 2 CFR 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires that all contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity, including the manner by which it will be affected and the basis for settlement. CONDITION: Our testing of nonpayroll expenditures showed purchase orders issued for contractual services for educational consulting services. Written contracts containing language that addresses termination for cause and for convenience by the school district, including the manner by which it will be affected and the basis for settlement, were not entered into. The district considered the purchase orders to be contracts for the services; however, there was no wording on the purchase orders that addressed termination for cause or convenience. CAUSE: The school district did not realize that written contract elements were required for contracts in excess of $10,000 and further did not realize that specific termination language should be included in the written contracts. EFFECT: The district did not comply with the provisions outlined in Appendix II to 2 CFR 200. QUESTIONED COSTS: None RECOMMENDATION: The district should familiarize itself with the requirements of Appendix II to Part 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-006. Equipment Management. (ALN 84.010 Title I grants to local educational agencies; ALN 84.424 Student support and academic enrichment grants, and ALN 84.425U ARP ESSER III) CRITERIA: 2 CFR 200.313(d)(1) requires for federal grants that property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, the acquisition date, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Since the State of Mississippi has more stringent criteria for tracking equipment inventory, the district must follow the following guidelines for equipment purchased with federal funds. Code Section 37-17-6(18) requires that the State Board of Education, acting through the Commission on School Accreditation, shall require each school district to comply with standards established by the State Department of Audit for the verification of fixed assets and the auditing of fixed assets records as a minimum requirement for accreditation. The State Department of Audit has issued an asset management manual to be used as a standard for verification of fixed assets. The school board has policies and procedures outlining the control and verification of fixed assets within the school district. As part of the asset management manual and local board policy, the district is charged with tracking assets meeting certain thresholds and performing physical verification of those assets at least annually. CONDITION: During our testing, we noted various pieces of equipment purchased with grant dollars totaling $92,555.68 that had not been added to the district?s subsidiary equipment records at the time of audit fieldwork. None of the purchased equipment met the threshold for depreciation; however, all the equipment met the threshold and criteria for tagging and inclusion in the subsidiary equipment records. These purchases were spread over three different federal grants as follows: ALN 84.010 Title I grants to local education agencies - $14,491.39 ALN 84.424 Student support and academic enrichments grants - $40,872.29 ALN 84.425U ARP ESSER III - $37,192.00 The school district stated that even though the equipment had not been added to the subsidiary records at the time of audit fieldwork, all equipment had been properly tagged. A physical inventory performed at the end of the 2021-2022 year would not have included all assets purchased during the 2021-2022 year because of the assets that had not been added to the inventory records at the time of purchase and tagging, therefore a year end inventory would have been incomplete. Our testing of the physical existence of selected fixed asset items revealed three (3) instances where assets appropriately included in the inventory records were not found at the time of testing. The three (3) assets not located were two (2) chromebooks and one (1) ipad with an original combined purchase price of $1,249.43. The assets were purchased from the following federal grant: ALN 84.425U ARP ESSER III - $1,249.43 CAUSE: The school district personnel failed to follow established policies for the recording of purchased equipment meeting the criteria for inclusion in equipment subsidiary records to the subsidiary records. EFFECT: The effect is a breakdown in controls surrounding the safeguarding of equipment purchased with federal dollars. Equipment purchased for use in the federal program could be used for purposes not related to the program or converted to personal use. QUESTIONED COSTS: None RECOMMENDATION: The district should follow established policies and procedures outlining the safeguarding of equipment purchased with federal grant dollars. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-004 ? Procurement. (ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER III, ALN 84.010 Title I grants to local educational agencies and ALN 84.367 Supporting effective instruction state grants) CRITERIA: Appendix II to 2 CFR 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires that all contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity, including the manner by which it will be affected and the basis for settlement. CONDITION: Our testing of nonpayroll expenditures showed purchase orders issued for contractual services for educational consulting services. Written contracts containing language that addresses termination for cause and for convenience by the school district, including the manner by which it will be affected and the basis for settlement, were not entered into. The district considered the purchase orders to be contracts for the services; however, there was no wording on the purchase orders that addressed termination for cause or convenience. CAUSE: The school district did not realize that written contract elements were required for contracts in excess of $10,000 and further did not realize that specific termination language should be included in the written contracts. EFFECT: The district did not comply with the provisions outlined in Appendix II to 2 CFR 200. QUESTIONED COSTS: None RECOMMENDATION: The district should familiarize itself with the requirements of Appendix II to Part 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-004 ? Procurement. (ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER III, ALN 84.010 Title I grants to local educational agencies and ALN 84.367 Supporting effective instruction state grants) CRITERIA: Appendix II to 2 CFR 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires that all contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity, including the manner by which it will be affected and the basis for settlement. CONDITION: Our testing of nonpayroll expenditures showed purchase orders issued for contractual services for educational consulting services. Written contracts containing language that addresses termination for cause and for convenience by the school district, including the manner by which it will be affected and the basis for settlement, were not entered into. The district considered the purchase orders to be contracts for the services; however, there was no wording on the purchase orders that addressed termination for cause or convenience. CAUSE: The school district did not realize that written contract elements were required for contracts in excess of $10,000 and further did not realize that specific termination language should be included in the written contracts. EFFECT: The district did not comply with the provisions outlined in Appendix II to 2 CFR 200. QUESTIONED COSTS: None RECOMMENDATION: The district should familiarize itself with the requirements of Appendix II to Part 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-004 ? Procurement. (ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER III, ALN 84.010 Title I grants to local educational agencies and ALN 84.367 Supporting effective instruction state grants) CRITERIA: Appendix II to 2 CFR 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires that all contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity, including the manner by which it will be affected and the basis for settlement. CONDITION: Our testing of nonpayroll expenditures showed purchase orders issued for contractual services for educational consulting services. Written contracts containing language that addresses termination for cause and for convenience by the school district, including the manner by which it will be affected and the basis for settlement, were not entered into. The district considered the purchase orders to be contracts for the services; however, there was no wording on the purchase orders that addressed termination for cause or convenience. CAUSE: The school district did not realize that written contract elements were required for contracts in excess of $10,000 and further did not realize that specific termination language should be included in the written contracts. EFFECT: The district did not comply with the provisions outlined in Appendix II to 2 CFR 200. QUESTIONED COSTS: None RECOMMENDATION: The district should familiarize itself with the requirements of Appendix II to Part 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-005. Allowed and Unallowed Costs. (ALN 84.425U ARP ESSER III) CRITERIA: 2 CFR 200.302 requires that a non-federal entity?s financial management systems must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. CONDITION: In our testing of the comparison of actual expenditures to budgeted amounts approved by the Mississippi Department of Education, we noted expenditures for the salaries and benefits for nurses exceeded approved budgeted amounts by $14,417.42. CAUSE: The school district failed to address unfavorable budgetary variances when actual expenditures exceeded approved budgeted amounts. EFFECT: The effect is both a breakdown in budgetary controls and unallowable program costs. Since these excess costs are less than $25,000.00, no costs will be questioned. QUESTIONED COSTS: None RECOMMENDATION: The district should limit expenditures to approved budgeted amounts for this grant. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-006. Equipment Management. (ALN 84.010 Title I grants to local educational agencies; ALN 84.424 Student support and academic enrichment grants, and ALN 84.425U ARP ESSER III) CRITERIA: 2 CFR 200.313(d)(1) requires for federal grants that property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, the acquisition date, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Since the State of Mississippi has more stringent criteria for tracking equipment inventory, the district must follow the following guidelines for equipment purchased with federal funds. Code Section 37-17-6(18) requires that the State Board of Education, acting through the Commission on School Accreditation, shall require each school district to comply with standards established by the State Department of Audit for the verification of fixed assets and the auditing of fixed assets records as a minimum requirement for accreditation. The State Department of Audit has issued an asset management manual to be used as a standard for verification of fixed assets. The school board has policies and procedures outlining the control and verification of fixed assets within the school district. As part of the asset management manual and local board policy, the district is charged with tracking assets meeting certain thresholds and performing physical verification of those assets at least annually. CONDITION: During our testing, we noted various pieces of equipment purchased with grant dollars totaling $92,555.68 that had not been added to the district?s subsidiary equipment records at the time of audit fieldwork. None of the purchased equipment met the threshold for depreciation; however, all the equipment met the threshold and criteria for tagging and inclusion in the subsidiary equipment records. These purchases were spread over three different federal grants as follows: ALN 84.010 Title I grants to local education agencies - $14,491.39 ALN 84.424 Student support and academic enrichments grants - $40,872.29 ALN 84.425U ARP ESSER III - $37,192.00 The school district stated that even though the equipment had not been added to the subsidiary records at the time of audit fieldwork, all equipment had been properly tagged. A physical inventory performed at the end of the 2021-2022 year would not have included all assets purchased during the 2021-2022 year because of the assets that had not been added to the inventory records at the time of purchase and tagging, therefore a year end inventory would have been incomplete. Our testing of the physical existence of selected fixed asset items revealed three (3) instances where assets appropriately included in the inventory records were not found at the time of testing. The three (3) assets not located were two (2) chromebooks and one (1) ipad with an original combined purchase price of $1,249.43. The assets were purchased from the following federal grant: ALN 84.425U ARP ESSER III - $1,249.43 CAUSE: The school district personnel failed to follow established policies for the recording of purchased equipment meeting the criteria for inclusion in equipment subsidiary records to the subsidiary records. EFFECT: The effect is a breakdown in controls surrounding the safeguarding of equipment purchased with federal dollars. Equipment purchased for use in the federal program could be used for purposes not related to the program or converted to personal use. QUESTIONED COSTS: None RECOMMENDATION: The district should follow established policies and procedures outlining the safeguarding of equipment purchased with federal grant dollars. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-004 ? Procurement. (ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER III, ALN 84.010 Title I grants to local educational agencies and ALN 84.367 Supporting effective instruction state grants) CRITERIA: Appendix II to 2 CFR 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires that all contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity, including the manner by which it will be affected and the basis for settlement. CONDITION: Our testing of nonpayroll expenditures showed purchase orders issued for contractual services for educational consulting services. Written contracts containing language that addresses termination for cause and for convenience by the school district, including the manner by which it will be affected and the basis for settlement, were not entered into. The district considered the purchase orders to be contracts for the services; however, there was no wording on the purchase orders that addressed termination for cause or convenience. CAUSE: The school district did not realize that written contract elements were required for contracts in excess of $10,000 and further did not realize that specific termination language should be included in the written contracts. EFFECT: The district did not comply with the provisions outlined in Appendix II to 2 CFR 200. QUESTIONED COSTS: None RECOMMENDATION: The district should familiarize itself with the requirements of Appendix II to Part 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-006. Equipment Management. (ALN 84.010 Title I grants to local educational agencies; ALN 84.424 Student support and academic enrichment grants, and ALN 84.425U ARP ESSER III) CRITERIA: 2 CFR 200.313(d)(1) requires for federal grants that property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, the acquisition date, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Since the State of Mississippi has more stringent criteria for tracking equipment inventory, the district must follow the following guidelines for equipment purchased with federal funds. Code Section 37-17-6(18) requires that the State Board of Education, acting through the Commission on School Accreditation, shall require each school district to comply with standards established by the State Department of Audit for the verification of fixed assets and the auditing of fixed assets records as a minimum requirement for accreditation. The State Department of Audit has issued an asset management manual to be used as a standard for verification of fixed assets. The school board has policies and procedures outlining the control and verification of fixed assets within the school district. As part of the asset management manual and local board policy, the district is charged with tracking assets meeting certain thresholds and performing physical verification of those assets at least annually. CONDITION: During our testing, we noted various pieces of equipment purchased with grant dollars totaling $92,555.68 that had not been added to the district?s subsidiary equipment records at the time of audit fieldwork. None of the purchased equipment met the threshold for depreciation; however, all the equipment met the threshold and criteria for tagging and inclusion in the subsidiary equipment records. These purchases were spread over three different federal grants as follows: ALN 84.010 Title I grants to local education agencies - $14,491.39 ALN 84.424 Student support and academic enrichments grants - $40,872.29 ALN 84.425U ARP ESSER III - $37,192.00 The school district stated that even though the equipment had not been added to the subsidiary records at the time of audit fieldwork, all equipment had been properly tagged. A physical inventory performed at the end of the 2021-2022 year would not have included all assets purchased during the 2021-2022 year because of the assets that had not been added to the inventory records at the time of purchase and tagging, therefore a year end inventory would have been incomplete. Our testing of the physical existence of selected fixed asset items revealed three (3) instances where assets appropriately included in the inventory records were not found at the time of testing. The three (3) assets not located were two (2) chromebooks and one (1) ipad with an original combined purchase price of $1,249.43. The assets were purchased from the following federal grant: ALN 84.425U ARP ESSER III - $1,249.43 CAUSE: The school district personnel failed to follow established policies for the recording of purchased equipment meeting the criteria for inclusion in equipment subsidiary records to the subsidiary records. EFFECT: The effect is a breakdown in controls surrounding the safeguarding of equipment purchased with federal dollars. Equipment purchased for use in the federal program could be used for purposes not related to the program or converted to personal use. QUESTIONED COSTS: None RECOMMENDATION: The district should follow established policies and procedures outlining the safeguarding of equipment purchased with federal grant dollars. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-004 ? Procurement. (ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER III, ALN 84.010 Title I grants to local educational agencies and ALN 84.367 Supporting effective instruction state grants) CRITERIA: Appendix II to 2 CFR 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires that all contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity, including the manner by which it will be affected and the basis for settlement. CONDITION: Our testing of nonpayroll expenditures showed purchase orders issued for contractual services for educational consulting services. Written contracts containing language that addresses termination for cause and for convenience by the school district, including the manner by which it will be affected and the basis for settlement, were not entered into. The district considered the purchase orders to be contracts for the services; however, there was no wording on the purchase orders that addressed termination for cause or convenience. CAUSE: The school district did not realize that written contract elements were required for contracts in excess of $10,000 and further did not realize that specific termination language should be included in the written contracts. EFFECT: The district did not comply with the provisions outlined in Appendix II to 2 CFR 200. QUESTIONED COSTS: None RECOMMENDATION: The district should familiarize itself with the requirements of Appendix II to Part 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-006. Equipment Management. (ALN 84.010 Title I grants to local educational agencies; ALN 84.424 Student support and academic enrichment grants, and ALN 84.425U ARP ESSER III) CRITERIA: 2 CFR 200.313(d)(1) requires for federal grants that property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, the acquisition date, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Since the State of Mississippi has more stringent criteria for tracking equipment inventory, the district must follow the following guidelines for equipment purchased with federal funds. Code Section 37-17-6(18) requires that the State Board of Education, acting through the Commission on School Accreditation, shall require each school district to comply with standards established by the State Department of Audit for the verification of fixed assets and the auditing of fixed assets records as a minimum requirement for accreditation. The State Department of Audit has issued an asset management manual to be used as a standard for verification of fixed assets. The school board has policies and procedures outlining the control and verification of fixed assets within the school district. As part of the asset management manual and local board policy, the district is charged with tracking assets meeting certain thresholds and performing physical verification of those assets at least annually. CONDITION: During our testing, we noted various pieces of equipment purchased with grant dollars totaling $92,555.68 that had not been added to the district?s subsidiary equipment records at the time of audit fieldwork. None of the purchased equipment met the threshold for depreciation; however, all the equipment met the threshold and criteria for tagging and inclusion in the subsidiary equipment records. These purchases were spread over three different federal grants as follows: ALN 84.010 Title I grants to local education agencies - $14,491.39 ALN 84.424 Student support and academic enrichments grants - $40,872.29 ALN 84.425U ARP ESSER III - $37,192.00 The school district stated that even though the equipment had not been added to the subsidiary records at the time of audit fieldwork, all equipment had been properly tagged. A physical inventory performed at the end of the 2021-2022 year would not have included all assets purchased during the 2021-2022 year because of the assets that had not been added to the inventory records at the time of purchase and tagging, therefore a year end inventory would have been incomplete. Our testing of the physical existence of selected fixed asset items revealed three (3) instances where assets appropriately included in the inventory records were not found at the time of testing. The three (3) assets not located were two (2) chromebooks and one (1) ipad with an original combined purchase price of $1,249.43. The assets were purchased from the following federal grant: ALN 84.425U ARP ESSER III - $1,249.43 CAUSE: The school district personnel failed to follow established policies for the recording of purchased equipment meeting the criteria for inclusion in equipment subsidiary records to the subsidiary records. EFFECT: The effect is a breakdown in controls surrounding the safeguarding of equipment purchased with federal dollars. Equipment purchased for use in the federal program could be used for purposes not related to the program or converted to personal use. QUESTIONED COSTS: None RECOMMENDATION: The district should follow established policies and procedures outlining the safeguarding of equipment purchased with federal grant dollars. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-004 ? Procurement. (ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER III, ALN 84.010 Title I grants to local educational agencies and ALN 84.367 Supporting effective instruction state grants) CRITERIA: Appendix II to 2 CFR 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires that all contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity, including the manner by which it will be affected and the basis for settlement. CONDITION: Our testing of nonpayroll expenditures showed purchase orders issued for contractual services for educational consulting services. Written contracts containing language that addresses termination for cause and for convenience by the school district, including the manner by which it will be affected and the basis for settlement, were not entered into. The district considered the purchase orders to be contracts for the services; however, there was no wording on the purchase orders that addressed termination for cause or convenience. CAUSE: The school district did not realize that written contract elements were required for contracts in excess of $10,000 and further did not realize that specific termination language should be included in the written contracts. EFFECT: The district did not comply with the provisions outlined in Appendix II to 2 CFR 200. QUESTIONED COSTS: None RECOMMENDATION: The district should familiarize itself with the requirements of Appendix II to Part 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-004 ? Procurement. (ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER III, ALN 84.010 Title I grants to local educational agencies and ALN 84.367 Supporting effective instruction state grants) CRITERIA: Appendix II to 2 CFR 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires that all contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity, including the manner by which it will be affected and the basis for settlement. CONDITION: Our testing of nonpayroll expenditures showed purchase orders issued for contractual services for educational consulting services. Written contracts containing language that addresses termination for cause and for convenience by the school district, including the manner by which it will be affected and the basis for settlement, were not entered into. The district considered the purchase orders to be contracts for the services; however, there was no wording on the purchase orders that addressed termination for cause or convenience. CAUSE: The school district did not realize that written contract elements were required for contracts in excess of $10,000 and further did not realize that specific termination language should be included in the written contracts. EFFECT: The district did not comply with the provisions outlined in Appendix II to 2 CFR 200. QUESTIONED COSTS: None RECOMMENDATION: The district should familiarize itself with the requirements of Appendix II to Part 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CONDITION: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-004 ? Procurement. (ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER III, ALN 84.010 Title I grants to local educational agencies and ALN 84.367 Supporting effective instruction state grants) CRITERIA: Appendix II to 2 CFR 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires that all contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity, including the manner by which it will be affected and the basis for settlement. CONDITION: Our testing of nonpayroll expenditures showed purchase orders issued for contractual services for educational consulting services. Written contracts containing language that addresses termination for cause and for convenience by the school district, including the manner by which it will be affected and the basis for settlement, were not entered into. The district considered the purchase orders to be contracts for the services; however, there was no wording on the purchase orders that addressed termination for cause or convenience. CAUSE: The school district did not realize that written contract elements were required for contracts in excess of $10,000 and further did not realize that specific termination language should be included in the written contracts. EFFECT: The district did not comply with the provisions outlined in Appendix II to 2 CFR 200. QUESTIONED COSTS: None RECOMMENDATION: The district should familiarize itself with the requirements of Appendix II to Part 200 ? Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-005. Allowed and Unallowed Costs. (ALN 84.425U ARP ESSER III) CRITERIA: 2 CFR 200.302 requires that a non-federal entity?s financial management systems must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. CONDITION: In our testing of the comparison of actual expenditures to budgeted amounts approved by the Mississippi Department of Education, we noted expenditures for the salaries and benefits for nurses exceeded approved budgeted amounts by $14,417.42. CAUSE: The school district failed to address unfavorable budgetary variances when actual expenditures exceeded approved budgeted amounts. EFFECT: The effect is both a breakdown in budgetary controls and unallowable program costs. Since these excess costs are less than $25,000.00, no costs will be questioned. QUESTIONED COSTS: None RECOMMENDATION: The district should limit expenditures to approved budgeted amounts for this grant. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-006. Equipment Management. (ALN 84.010 Title I grants to local educational agencies; ALN 84.424 Student support and academic enrichment grants, and ALN 84.425U ARP ESSER III) CRITERIA: 2 CFR 200.313(d)(1) requires for federal grants that property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, the acquisition date, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Since the State of Mississippi has more stringent criteria for tracking equipment inventory, the district must follow the following guidelines for equipment purchased with federal funds. Code Section 37-17-6(18) requires that the State Board of Education, acting through the Commission on School Accreditation, shall require each school district to comply with standards established by the State Department of Audit for the verification of fixed assets and the auditing of fixed assets records as a minimum requirement for accreditation. The State Department of Audit has issued an asset management manual to be used as a standard for verification of fixed assets. The school board has policies and procedures outlining the control and verification of fixed assets within the school district. As part of the asset management manual and local board policy, the district is charged with tracking assets meeting certain thresholds and performing physical verification of those assets at least annually. CONDITION: During our testing, we noted various pieces of equipment purchased with grant dollars totaling $92,555.68 that had not been added to the district?s subsidiary equipment records at the time of audit fieldwork. None of the purchased equipment met the threshold for depreciation; however, all the equipment met the threshold and criteria for tagging and inclusion in the subsidiary equipment records. These purchases were spread over three different federal grants as follows: ALN 84.010 Title I grants to local education agencies - $14,491.39 ALN 84.424 Student support and academic enrichments grants - $40,872.29 ALN 84.425U ARP ESSER III - $37,192.00 The school district stated that even though the equipment had not been added to the subsidiary records at the time of audit fieldwork, all equipment had been properly tagged. A physical inventory performed at the end of the 2021-2022 year would not have included all assets purchased during the 2021-2022 year because of the assets that had not been added to the inventory records at the time of purchase and tagging, therefore a year end inventory would have been incomplete. Our testing of the physical existence of selected fixed asset items revealed three (3) instances where assets appropriately included in the inventory records were not found at the time of testing. The three (3) assets not located were two (2) chromebooks and one (1) ipad with an original combined purchase price of $1,249.43. The assets were purchased from the following federal grant: ALN 84.425U ARP ESSER III - $1,249.43 CAUSE: The school district personnel failed to follow established policies for the recording of purchased equipment meeting the criteria for inclusion in equipment subsidiary records to the subsidiary records. EFFECT: The effect is a breakdown in controls surrounding the safeguarding of equipment purchased with federal dollars. Equipment purchased for use in the federal program could be used for purposes not related to the program or converted to personal use. QUESTIONED COSTS: None RECOMMENDATION: The district should follow established policies and procedures outlining the safeguarding of equipment purchased with federal grant dollars. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.