FINDING 2024-001
Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment
Summary of Finding:
Federal Agency: Department of Education
Federal Programs: COVID-19 - Special Education Grants to States; COVID-19 - Special Education Preschool Grants
Assistance Listings...
FINDING 2024-001
Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment
Summary of Finding:
Federal Agency: Department of Education
Federal Programs: COVID-19 - Special Education Grants to States; COVID-19 - Special Education Preschool Grants
Assistance Listings Numbers: 84.027; 84.173
Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP; 22619-042-ARP
Pass-Through Entity: Indiana Department of Education
Compliance Requirement(s): Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Modified Opinion
Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD
Contact Phone Number and Email Address: 260-868-2125; dmason@dkeschools.com
Views of Responsible Officials:
We concur with the findings.
Description of Corrective Action Plan:
The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds
which were fully expended during the audit period. All future expenditures triggering procurement and suspension and
debarment requirements will include implementing the following procurement policies.
Reference Procurement Standards 2 CFR 200.318
Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with
federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must
be verified in one of three ways:
1. Checking the System for Award Management (SAM) (www.SAM.gov)
2. Collecting a certificate from that contractor.
3. Adding a clause or condition to the covered transaction with that contractor. (Recommended)
**Proper verification and documentation must be sent to the LEA for audit purposes.
Methods of Procurement
Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local
rules have more restrictive thresholds, the most restrictive rule must be followed.
E
INDIANA STATE BOARD OF ACCOUNTS
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Informal Procurement Procedures
1. Micro-purchase (0-$50,000)
Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000
Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be
reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA.
2. Small Purchase ($50,000 – $150,000)
Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small
purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be
presented along with the purchase order prior to being approved by the LEA.
Formal Procurement Procedures
1. Sealed Bids (above $150,000)
Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to
the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding
documentation must be presented to the LEA prior to any final approval or purchases being made.
2. Competitive Proposals (above $150,000)
The Request for Proposal method is used for procurements in which factors other than cost play a significant role.
Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is
either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract
using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of
goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper
advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented
to the LEA prior to any final approval or purchases being made.
Noncompetitive (Sole Source)
All sole source procurements require adequate written justification and must be attached to the corresponding purchase
order or payment.
Anticipated Completion Date:
All expenditures initiated after March 12, 2025