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FINDING 2022-005Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 ? School Breakfast Program, National SchoolLunch Program, COVID-19 ? National School Lunch Program, Summer Food Ser...
FINDING 2022-005Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 ? School Breakfast Program, National SchoolLunch Program, COVID-19 ? National School Lunch Program, Summer Food Service Program, COVID-19 ?Summer Food Service ProgramALN Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersContact Person Responsible for Corrective Action: Chad Yencer - SuperintendentContact Phone Number: 765-348-7550Views of Responsible Official: We concur with this findingDescription of Corrective Action Plan:BCS has established the following internal controls to ensure compliance:1. Internal Control: When a purchase is made at $10,000 or more using Federal Funds, thesuperintendent will require that any vendors selected are in compliance with theProcurement and Suspension and Debarment compliance requirement by completing one ofthe following quality checks with each vendor prior to purchase:a. Checking the federal System for Award Management (SAM) database athttps://sam.gov/content/exclusions and maintain a screenshot of the search results.b. Collect a certification from the vendor directlyc. Add a clause or condition to the covered transaction with the vendorAnticipated Completion Date:This corrective action will be implemented and completed immediately with any purchase made that meets theabove threshold.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of TreasuryFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (...
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of TreasuryFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersRecommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retainedfor audit purposes.Explanation of disagreement with audit finding: There is no disagreement with the auditfinding.Action taken in response to finding This finding was a result of only one vendor being availableat the time. The Office of Purchasing and Grants staff will comply with the requirement forobtaining quotes and document any exceptions if two quotes cannot obtained.Name(s) of the contact person(s) responsible for corrective action: BCPS Office ofPurchasing staff, grant accountants/fiscal staff.Planned completion date for corrective action plan: For immediate implementation andongoing.
Recommendation: We recommend that the College ensure its policies and procedures over procurement are being enforced to ensure reasonable prices and rates. Specifically, the College should consider training employees that regulations do apply when a single vendor is being used for a good or service...
Recommendation: We recommend that the College ensure its policies and procedures over procurement are being enforced to ensure reasonable prices and rates. Specifically, the College should consider training employees that regulations do apply when a single vendor is being used for a good or service, yet the charges are split amongst various funding sources.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action in Response to Finding: The College will implement training and procedural changes during the grant budgeting process and in the post-award process to ensure documentation of reasonable prices and rates to include training related to handling vendors who may be used across multiple funding sources.Name of the contact person responsible for corrective action: Tess Powers, Director of Faculty Research Support (719) 389-6318Planned completion date for corrective action plan: May 1, 2023
FINDING 2022-001Contact Person Responsible for Corrective Action: Mayor Terry AmickContact Phone Number: 812-752-3169Views of Responsible Official: I concur with the findings.Description of Corrective Action Plan: The City plans to review existing policies and procedures andmake any needed changes t...
FINDING 2022-001Contact Person Responsible for Corrective Action: Mayor Terry AmickContact Phone Number: 812-752-3169Views of Responsible Official: I concur with the findings.Description of Corrective Action Plan: The City plans to review existing policies and procedures andmake any needed changes to endure that they are in compliance with the federal compliancerequirements for procurement as well as suspension and debarment. Furthermore, controls will beestablished to ensure that the City?s policies related to compliance with the federal compliancerequirements for procurement as well as suspension and debarment are followed.Anticipated Completion Date: December 31, 2023
2) Finding 2022-03 - The School failed to obtain price quotations from multiple sources for a purchase that exceeded $10,000. a. Implementation of plan of action - Management will review its procurement policies to ensure that the School complies with 2 CFR 200.320 of the Uniform Guidance. b. Implem...
2) Finding 2022-03 - The School failed to obtain price quotations from multiple sources for a purchase that exceeded $10,000. a. Implementation of plan of action - Management will review its procurement policies to ensure that the School complies with 2 CFR 200.320 of the Uniform Guidance. b. Implementation date - Anticipated completion June 30, 2024. c. Persons responsible for the implementation - The Board of Directors and Head of School.
View Audit 308126 Questioned Costs: $1
Views of Responsible Officials and Planned Corrective Actions: Astraea created a best practice procurement policy in December 2021 that was implemented in February 2022 (i.e. Q3 of FY2022). Prior to December 2021, procurement practices were not standardized across the organization. Since implementat...
Views of Responsible Officials and Planned Corrective Actions: Astraea created a best practice procurement policy in December 2021 that was implemented in February 2022 (i.e. Q3 of FY2022). Prior to December 2021, procurement practices were not standardized across the organization. Since implementation of the current procurement policy, all staff members have been trained on the procurement policy, and the Finance and Operation teams have developed internal processes to ensure that all procurement flows through the organization are documented and in compliance with 2 CFR 200. With the policy in place, we recognize that implementation across teams is critical and are actively training people managers to improve oversight and improve implementation. Anticipated Completion Date: January 31, 2024 Responsible Official: Associate Director, Grants Management and Compliance; Director of Program Operations
Finding 394234 (2022-002)
Significant Deficiency 2022
Planned Corrective Action: Team Rubicon will institute policies and procedures to ensure compliance with applicable procurement guidelines when accepting federal awards. These will include prohibition against contracts which could be influenced by a perceived or actual conflict of interest, document...
Planned Corrective Action: Team Rubicon will institute policies and procedures to ensure compliance with applicable procurement guidelines when accepting federal awards. These will include prohibition against contracts which could be influenced by a perceived or actual conflict of interest, documentation of a search for suspended and debarred parties, and guidelines for approved methods of procurement (including specific situations where noncompetitive procurement may be appropriate, and documentation to be required if so).
Finding 393830 (2022-004)
Significant Deficiency 2022
View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will...
View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: 5 H49MC00119-21-00 / 6 H49MC00119-20-01 2022-008: Procurement – Material Weakness Recommendation: We recommend the Organization strengthen its policies and procedures to ensure procurement is adequately doc...
U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: 5 H49MC00119-21-00 / 6 H49MC00119-20-01 2022-008: Procurement – Material Weakness Recommendation: We recommend the Organization strengthen its policies and procedures to ensure procurement is adequately documented so that goods and services are purchased in accordance with Uniform Guidance and other federal guidelines. Grantee Response and Corrective Action Plan 2022-008: We acknowledge the gap identified between our policy framework and its execution, particularly in the area of maintaining supporting documentation. The Center for Black Women’s Wellness has approved policies that are designed to meet the requirements of the Uniform Guidance; however, we recognize that in practice, implementation has been inconsistent. Notably, of the sixty transactions reviewed, eight were found lacking in supporting documentation. To address this issue, we have already taken corrective measures by reinforcing our procedures and ensuring that appropriate staff are aware of these requirements. In 2024, we strengthened our oversight by engaging a Contractual CFO who will be instrumental in implementing these enhanced controls. This effort is part of our ongoing commitment to ensure full compliance and transparency in our procurement processes, thereby aligning our practices more closely with our established policies. Responsible Parties: Jemea Dorsey, CEO Date Corrected: April 30, 2024
View Audit 303667 Questioned Costs: $1
Material Weakness in Internal Control over Compliance Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review potential contractors to determine they arenot suspended or debarred. These procedures should include documenting the date t...
Material Weakness in Internal Control over Compliance Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review potential contractors to determine they arenot suspended or debarred. These procedures should include documenting the date that suspension and debarment verifications are made. In addition, we recommend The Organization formally adopt a Procurement, Suspension and Debarment policy in accordance with Uniform Guidance. There is no disagreement with the audit finding. Action taken in response to finding: Since Fall/Winter 2023, we have reviewed the Organization’s controls for procurement, suspension, and debarment, including the process for reviewing potential contractors for suspension and debarment. We have expanded our controls and increased training to improve control strength, and we have formally adopted a Procurement, Suspension and Debarment policy in accordance with Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 04/01/2024
Action Taken: Range Mental Health Center, Inc. and Subsidiaries will adopt a documented procurement policy consistent with the standards of 2 CRF section 200.317 through 200.320 to use procurement of the acquisition of property or service required under federal awards or sub-awards.
Action Taken: Range Mental Health Center, Inc. and Subsidiaries will adopt a documented procurement policy consistent with the standards of 2 CRF section 200.317 through 200.320 to use procurement of the acquisition of property or service required under federal awards or sub-awards.
Finding 390130 (2022-004)
Significant Deficiency 2022
1. The Center will retain evidence of competitive bidding, unless an emergency or other situation precluding the delay of competitive bidding has arisen (in which case, the Center will retain the evidence and rationale justifying the sole source contract). The Center will retain verification of susp...
1. The Center will retain evidence of competitive bidding, unless an emergency or other situation precluding the delay of competitive bidding has arisen (in which case, the Center will retain the evidence and rationale justifying the sole source contract). The Center will retain verification of suspension and debarment for all potential contract service providers. The Center notes that one of the contracts selected for testing arose during an emergency situation (flooding). 2. CFO will ensure that all invoices and supporting documentation are retained. ED and/or Director of Legal Services (depending on amount of expenditure, both may be required) will approve electronic payments in Bill.com. Approval of expenses paid with paper checks will be indicated by signature of checks after reviewing accompanying support.
View Audit 301014 Questioned Costs: $1
Coronavirus State and Local Fiscal Recovery Funds- Assistance Listing No. 21.027 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followeed and to monitor the a...
Coronavirus State and Local Fiscal Recovery Funds- Assistance Listing No. 21.027 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followeed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures will help ensure compliance ith Compilance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: there is no disagreement with the audit finding. Action taken in response to finding: The Organization will develop a written procurement policy and will develop controls to monitor when expenses approach the various procurement thresholds to help us complete the appropriate procurement procedures in compliance with out policy. Name(s) of the contact person(s) responsible for corrective action: Frank Caruso, Director of Finance and Operations. Planned completion date for corrective action plan: Sarted in January 2024. If the the U.S. Department of the Treasury has questions regarding this plan, please call Frank Caruso, Director of Finance and Operations at (602) 241-4645.
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncomplia...
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $21,440.00 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Corrective Action Plan: The Harris County SNP will review internal controls and apply correct procedures to all purchases made. Estimated Completion Date: June 30, 2024 Contact Person: Meghan L. Ceja Telephone: 706-628-4206 Email: ceja-m@harris.k12.ga.us
View Audit 296666 Questioned Costs: $1
FA 2022-002 Strengthen Controls over Procurement Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entit...
FA 2022-002 Strengthen Controls over Procurement Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Numbers: 225GA324N1199 (Year: 2022) Questioned Costs: None Identified Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Corrective Action Plans: The Hancock County School District has implemented the bid process to ensure that the School District’s procurement procedures are followed. Estimated Completion Date: June 30, 2024 Contact Person: Matthias Jones, Finance Director Telephone: (706) 444-5775 Ext. 125 Email: mjones@hancock.k12.ga.us
Finding 375837 (2022-004)
Significant Deficiency 2022
Procurement and Suspension and Debarment Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followe...
Procurement and Suspension and Debarment Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants. Name(s) of the contact person(s) responsible for corrective action: Cate Wylie Planned completion date for corrective action plan: December 31, 2024
Type of Finding: Material Weakness in Internal Control over Compliance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.243 Federal Award Identi...
Type of Finding: Material Weakness in Internal Control over Compliance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.243 Federal Award Identification Number and Year: H79TI081935 – 2022, H79TI080298 – 2022, H79TI085517 – 2022 Pass-Through Agency: Pierce County Pass-Through Number(s): SC-107323, SC-105454, SC-110121 Award Period: May 31, 2022 through May 30, 2023, September 30, 2017 through September 29, 2022, September 30, 2022 through September 29, 2027. Criteria or specific requirement: 2 CFR 200.320 requires non-federal entities to have and use documented procurement procedures. 2 CFR 200.318(i) states that "the non-Federal entity must maintain record sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price". In addition, 2 CFR 200.320(a)(2)(i) states that "... If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity". 2 CFR 180.300 states that before entering into a covered transaction with another person at the next lower tier, an entity must verify that the person with whom they intend to do business with is not excluded or disqualified. This can be done by “(a) Checking SAM exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person”. Condition: The Alliance does not have a written procurement, suspension and debarment policy nor procedures in place at the time of the audit in compliance with Uniform Guidance. For procurement, CLA tested all purchases exceeding $3,500 (the minimum micropurchase threshold before it was increased by the FAR to $10,000 for those with an established policy). For the 5 sampled procurement selections, documentation was not retained for the adequate number of price comparisons prior to exercising the procurement, as required by 2 CFR 200.320. For suspension and debarment, CLA tested all payments to vendors exceeding $25,000 as established by Uniform Guidance. Of the 3 tested, there was no documentary evidence that procedures were performed prior to entering into the covered transaction using the allowable methods as described at 2 CFR 180.300. Questioned costs: Undeterminable. Context: Procurement: A sample of 5 was made from a population of 16 procurement transactions charged to the major program that exceeded $3,500 (the minimum micropurchase threshold before it was increased by the FAR to $10,000 for those with an established policy), amounting to $48,099. Of the 5 sampled costs, all were found to be out of compliance with the Procurement requirements, as a written procurement policy was not in place and documentation was not retained for the adequate number of price comparisons. Suspension and Debarment: A sample of 3 (entire population) was made from a population of 3 vendors who received payments exceeding $25,000. Of the 3 sampled vendors, there was no documentary evidence that procedures were performed prior to entering into the covered transaction using the allowable methods as described at 2 CFR 180.300. Cause: Management believes procurement, suspension and debarment standards apply only to the awarding agency, and not to the Alliance. Effect: Purchases may occur that do not follow the procurement, suspension and debarment standards as required by Uniform Guidance, and contracts to vendors that had been suspended or debarred could be awarded and not detected. Repeat Finding: No. Recommendation: We recommended that the Alliance design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred. These procedures should include documenting the date that suspension and debarment verifications are made. In addition, we recommended the Alliance to formally adopt a Procurement, Suspension and Debarment policy in accordance with Uniform Guidance. The Alliance followed this recommendation, pairing prior (non-federally implicated) procurement processes and expenditures. Views of responsible officials: Pierce County Alliance has enjoyed the a decades long relationship with its prior firm. At no time during that relationship has the need for a Procurement, Suspension and Debarment policy been noted as a deficiency, nor has a finding been issued. Corrective Action: Pierce County Alliance will continue to revise its policies and procedures and controls related to Procurement, Suspension and Debarment, including procedures to review potential contractors for suspension or debarment and to achieve full compliance with the Uniform Guidance.
Finding 372581 (2022-002)
Significant Deficiency 2022
Views of Responsible Officials: The sample was chosen prior to the implementation of our procurement policy. The procurement policy was updated after recommendations made in the audit completed in late 2022. Since the conclusion of 2022, our personnel have undergone comprehensive training on procure...
Views of Responsible Officials: The sample was chosen prior to the implementation of our procurement policy. The procurement policy was updated after recommendations made in the audit completed in late 2022. Since the conclusion of 2022, our personnel have undergone comprehensive training on procurement procedures and have diligently adhered to the established guidelines as required.
FA 2022-003 Improve Controls over Procurement Compliance Requirement: Procurement Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: ...
FA 2022-003 Improve Controls over Procurement Compliance Requirement: Procurement Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 84.027 - Special Education Grants to States 84.173 – Special Education Preschool Grants Federal Award Numbers: HO27A200073(Year: 2021), HO27A210073 (Year: 2022), HO27X210073 (Year: 2022), S371C190016-19A (Years: 2017-21) Questioned Costs: None Identified Description: A review of expenditures charged to the Special Education Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Corrective Action Plans: [Insert Corrective Action Plan(s) Here] Estimated Completion Date: A review of costs and expenditures for all purchases and contracts involving rates of pay for the purpose of education students with disabilities will be completed prior to the approval of purchases and contractual agreements. A minimum of 2 quotes per expenditure and/or contracted service agreement will be procured prior to approval of the expenditure and/or contractual agreement. For contractual agreements, the student services director will be responsible for obtaining quotes, and the individual requesting the purchase of required items will be responsible for obtaining and providing quotes to the director prior to approval. These records will be kept on file within the student services department. Contact Person: Angela Williams, Superintendent Telephone: 706-554-5101 Email: amwilliams@burke.k12.ga.us
FA 2022-002 Improve Controls over Procurement Compliance Requirement: ‘Procurement Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. ...
FA 2022-002 Improve Controls over Procurement Compliance Requirement: ‘Procurement Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.371C – Comprehensive Literacy Development Federal Award Number: S371C190016-19A (Years: 2017-21) Questioned Costs: ‘$177,213.73 Description: A review of expenditures charged to the Comprehensive Literacy Development program revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Corrective Action Plans: The Comprehensive Literacy Director will review and update the current procedures to ensure that the required procurement methods are properly identified and followed, and that required procurement documentation is properly identified, safeguarded, and retained. Estimated Completion Date: May 1, 2024 Contact Person: Angela Williams, Superintendent Telephone: 706-554-5101 Email: amwilliams@burke.k12.ga.us
View Audit 292408 Questioned Costs: $1
Finding 370645 (2022-003)
Material Weakness 2022
There is no disagreement with the finding. The City will establish a procurement policy that is in compliance with Uniform Guidance standards and follow that policy for all future federal grants. Name of responsible official: Amanda Toney, Finance Director Expected date of completion: The planned c...
There is no disagreement with the finding. The City will establish a procurement policy that is in compliance with Uniform Guidance standards and follow that policy for all future federal grants. Name of responsible official: Amanda Toney, Finance Director Expected date of completion: The planned completion date is September 1, 2024
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 34 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.
2022-005 Significant Deficiency in Controls over Compliance: Administrative Requirements of Uniform Guidance-Administrative Policies The schools have documented their administrative policies effective 3/1/2023.
2022-005 Significant Deficiency in Controls over Compliance: Administrative Requirements of Uniform Guidance-Administrative Policies The schools have documented their administrative policies effective 3/1/2023.
FINDING 2022-004 Contact Person Responsible for Corrective Action: Sue Hart Contact Phone Number: 812-752-8921 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Each vendor who has received payment from the school district from federal Child Nutrition ...
FINDING 2022-004 Contact Person Responsible for Corrective Action: Sue Hart Contact Phone Number: 812-752-8921 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Each vendor who has received payment from the school district from federal Child Nutrition funds, or is expected to in the future, shall be required to have at least one of the following filed with the school district each year: 1) SAM Exclusions without the vendor being listed as excluded or disqualified; or, 2) Certification of the vendor not being excluded or disqualified; or, 3) Including a clause or condition on any and all contracts or invoices confirming the vendor is not excluded or disqualified. The Director of Food Services shall maintain files with evidence of the above documentation and it shall be updated at least annually and no fewer than once per calendar year. In addition, the Director shall ensure price or rate quotes are acquired from all vendors the Director reasonably expects to pay more than the micro-purchase threshold and contracts shall be executed with vendors when purchases are between $50,000 and $150,000. Such contracts shall also be Board approved with copies uploaded to the Gateway system for ease of access by SBOA or the district in the future. Anticipated Completion Date: June 2023
REFERENCE # 2022-001 PROCUREMENT SUSPENSION AND DEBARMENT ? MATERIAL WEAKNESS- NON-COMPLIANCE Program Name/ALN Emergency Solutions Grant Program (ALN # 14.231) Criteria: As per ? 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, co...
REFERENCE # 2022-001 PROCUREMENT SUSPENSION AND DEBARMENT ? MATERIAL WEAKNESS- NON-COMPLIANCE Program Name/ALN Emergency Solutions Grant Program (ALN # 14.231) Criteria: As per ? 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition/Context: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR ? 200.318 General procurement standards. We selected two (2) vendors for procurement Suspension and Debarment compliance testing of total population of 2 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: ? To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. ? To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Questioned Costs: Cannot be determined Recommendation: We recommend that the Division must: (1) document procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. (2) The Division?s documented procurement procedures must conform to the procurement standards identified in ?? 200.318 through 200.327. . Corrective Action Plan: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. Step 1 Action Date: Ongoing Final Implementation Date: 9/30/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710
View Audit 82228 Questioned Costs: $1
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