FINDING 2022-002
Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and
Debarment
Summary of Finding:
An effective internal control system was not in place at the School Corporation to ensure
compliance with requirements related to the grant agreement and the Procurement ...
FINDING 2022-002
Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and
Debarment
Summary of Finding:
An effective internal control system was not in place at the School Corporation to ensure
compliance with requirements related to the grant agreement and the Procurement and Suspension
and Debarment compliance requirement.
The School Corporation had not designed or implemented adequate policies or procedures
to ensure that proper procurement procedures for small purchases were followed. There was no
oversight, review, or approval process in place and documented at the School Corporation to
ensure proper procedures were followed and price or rate quotations were obtained, or
documentation to support limited procurement procedures conducted.
Federal regulations allow for informal procurement methods when the value of the
procurement for property or services does not exceed the simplified acquisition threshold, which is
set at $150,000 per Indiana Code. This informal process allows for methods other than the formal
bid process. The informal process is divided between two methods based on thresholds. Micropurchases,
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.
The School Corporation did not obtain price or rate quotes for the five vendors tested that
was less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micropurchase
threshold. Documentation detailing the history of procurement, which must include the
reason for the procurement method used, was not available for audit.
The School Corporation also did not follow procurement requirements for contracted
services which exceeded the simplified acquisition threshold of $150,000. The School Corporation
did not correctly procure a contract for the one vendor that exceeded the simplified acquisition
threshold. Additionally, the School Corporation did not adequately maintain documentation of the
procurement history or rationale. Finally, the School Corporation did not verify that this vendor was
not excluded or disqualified from participation in federal assistance programs or activities.
Contact Person Responsible for Corrective Action: Matthew Miles, CFO
Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us
Views of Responsible Officials:
We concur with the finding.
Description of Corrective Action Plan:
The School District will obtain 3 quotes or do a bid process in the future. If there is limited
availability, we will document the reason 3 quotes are not possible. Additionally, the District
INDIANA STATE BOARD OF ACCOUNTS
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will check for suspension and debarment, create a write-up of our findings, and obtain Board
approval for the contract.
Anticipated Completion Date:
The School District will implement changes described in the Corrective Action Plan February
in 2024.