2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-004 Unmet Need Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Special Tests ? Unmet Need Material Weakness in Internal Control over Compliance Criteria: To ensure that funding is focused on unmet need, the Commission requires schools, library, and consortia to certify, as part of their funding application, that they are only seeking support for eligible equipment and/or broadband provided to students and school staff who would otherwise lack access to connected devices and/or broadband connectivity sufficient to engage in remote learning. At the application stage, school need only provide the best estimates of their unmet need. They may use whatever method they deem appropriate for estimating unmet need and are not required to provide any documentation to support these estimates when they submit their ECF FCC Form 471 application. When schools file for requests for reimbursement, however, they should only request reimbursement for eligible equipment and services provided to students or school staff who would otherwise lack broadband services and/or devices sufficient to engage in remote learning. For example, if a school requested ECF funding to support the broadband services at the homes of 100 students based on an estimate of those that lacked services, but it determines during the school year that only 90 students have unmet need, the school should only seek reimbursement for the services provided to those 90 students. Schools may also be asked to provide documentation to support actual costs of assigned equipment and/or services after funds have been committed). Condition: During the fiscal year ended June 30, 2022, it does not appear that the District had a control in place to monitor unmet need and to ensure that the federal reimbursement was for students or staff who have an unmet need for the devices reimbursed by the federal program. Cause: The District does not appear to have a consistent process in place to validate unmet need requirements of the District for purposes of this federal program. Effect: The District could be out of compliance with federal requirements by receiving a reimbursement of federal funds for ECF devices and other services that were not provided to students or staff with unmet needs. Context/Sampling: While the District does monitor if there is an unmet need when providing devices, they do not have an established control to ensure there is an unmet need before reimbursement is requested, and therefore, no control testing could be performed on a sample of items. Repeat Finding From Prior Year: No Questioned costs: None reported. Recommendation: Control procedures should be implemented to ensure that devices/services are provided to students and staff with unmet needs (i.e. application for checkout with identifying reason for the need). Views of Responsible Officials: The Technology Services team did determine the unmet need for the devices utilizing a parent survey but did not have additional documentation to support that a control was in place to ensure unmet need before requesting reimbursement. We will ensure we have documentation that the unmet need still exists with any future requests for federal reimbursement.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.
2022-004 Unmet Need Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Special Tests ? Unmet Need Material Weakness in Internal Control over Compliance Criteria: To ensure that funding is focused on unmet need, the Commission requires schools, library, and consortia to certify, as part of their funding application, that they are only seeking support for eligible equipment and/or broadband provided to students and school staff who would otherwise lack access to connected devices and/or broadband connectivity sufficient to engage in remote learning. At the application stage, school need only provide the best estimates of their unmet need. They may use whatever method they deem appropriate for estimating unmet need and are not required to provide any documentation to support these estimates when they submit their ECF FCC Form 471 application. When schools file for requests for reimbursement, however, they should only request reimbursement for eligible equipment and services provided to students or school staff who would otherwise lack broadband services and/or devices sufficient to engage in remote learning. For example, if a school requested ECF funding to support the broadband services at the homes of 100 students based on an estimate of those that lacked services, but it determines during the school year that only 90 students have unmet need, the school should only seek reimbursement for the services provided to those 90 students. Schools may also be asked to provide documentation to support actual costs of assigned equipment and/or services after funds have been committed). Condition: During the fiscal year ended June 30, 2022, it does not appear that the District had a control in place to monitor unmet need and to ensure that the federal reimbursement was for students or staff who have an unmet need for the devices reimbursed by the federal program. Cause: The District does not appear to have a consistent process in place to validate unmet need requirements of the District for purposes of this federal program. Effect: The District could be out of compliance with federal requirements by receiving a reimbursement of federal funds for ECF devices and other services that were not provided to students or staff with unmet needs. Context/Sampling: While the District does monitor if there is an unmet need when providing devices, they do not have an established control to ensure there is an unmet need before reimbursement is requested, and therefore, no control testing could be performed on a sample of items. Repeat Finding From Prior Year: No Questioned costs: None reported. Recommendation: Control procedures should be implemented to ensure that devices/services are provided to students and staff with unmet needs (i.e. application for checkout with identifying reason for the need). Views of Responsible Officials: The Technology Services team did determine the unmet need for the devices utilizing a parent survey but did not have additional documentation to support that a control was in place to ensure unmet need before requesting reimbursement. We will ensure we have documentation that the unmet need still exists with any future requests for federal reimbursement.
2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.