FINDING 2024-004
Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and
Debarment
Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager,
DeKalb Co. Eastern CSD
Contact Phone Number and Email Address: 260-868-2125
Views of Responsible Officials: We...
FINDING 2024-004
Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and
Debarment
Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager,
DeKalb Co. Eastern CSD
Contact Phone Number and Email Address: 260-868-2125
Views of Responsible Officials: We concur with the finding.
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.
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