FINDING 2023-005
Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment
Summary of Finding:
Procurement
Federal regulations allow for informal procurement methods when the value of the procurement for goods
or services does not exceed the simplified acquisition ...
FINDING 2023-005
Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment
Summary of Finding:
Procurement
Federal regulations allow for informal procurement methods when the value of the procurement for goods
or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000.
However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid
process. The informal process is divided between two methods based on thresholds. Micro-purchases,
typically for those purchases $10,000 or under, and small purchase procedures for those purchases
above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may
be awarded without soliciting competitive price rate quotations. If small purchase procedures are used,
then price or rate quotations must be obtained from an adequate number of qualified sources. If it is
determined a single source provider can be used for a small purchase, documentation must be retained
supporting the determination. The Cooperative did not adhere to the requirements necessary for them to
be in compliance with the procurement of small purchases during the audit period.
Suspension and Debarment
The School Corporation did not have internal controls in place to ensure compliance with the suspension
and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure
all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As
such, the Cooperative never entered into a contract, although their payments to the vendor exceeded
$50,000. The Cooperative did not perform procedures to ensure that the vendor was not suspended or
debarred from participation in federal programs.
Contact Person Responsible for Corrective Action: Julie Dudley
Contact Phone Number and Email Address: 812.537.7205 jdudley@lburg.k12.in.us
Views of Responsible Officials:
We concur with the finding.
Description of Corrective Action Plan:
The ROD Special Education Cooperative will make notes in the Board Minutes regarding the fact that
only one vendor can provide specific services prior to entering into a contract or purchasing said
services. Each company providing services will be checked on the SAM.gov website to ensure that
the vendor has not been suspended or debarred. This documentation will be provided to the ROD
board for review, and our Superintendent is a member of that board.
Anticipated Completion Date:
February 1, 2024