2022 ? 002 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).? Condition: During our testing, we noted Suspension and debarment checks were not performed in accordance with applicable requirements on 3 out of the 6 contracts sampled. Questioned costs: None Context: Using a statistically valid sample, CLA selected 6 covered transactions for testing. 3 of the samples selected did not have a suspension and debarment certification prior to entering in a contract with the vendor. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the Brownsburg Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 002 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).? Condition: During our testing, we noted Suspension and debarment checks were not performed in accordance with applicable requirements on 3 out of the 6 contracts sampled. Questioned costs: None Context: Using a statistically valid sample, CLA selected 6 covered transactions for testing. 3 of the samples selected did not have a suspension and debarment certification prior to entering in a contract with the vendor. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the Brownsburg Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 002 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).? Condition: During our testing, we noted Suspension and debarment checks were not performed in accordance with applicable requirements on 3 out of the 6 contracts sampled. Questioned costs: None Context: Using a statistically valid sample, CLA selected 6 covered transactions for testing. 3 of the samples selected did not have a suspension and debarment certification prior to entering in a contract with the vendor. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the Brownsburg Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 002 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).? Condition: During our testing, we noted Suspension and debarment checks were not performed in accordance with applicable requirements on 3 out of the 6 contracts sampled. Questioned costs: None Context: Using a statistically valid sample, CLA selected 6 covered transactions for testing. 3 of the samples selected did not have a suspension and debarment certification prior to entering in a contract with the vendor. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the Brownsburg Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 002 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).? Condition: During our testing, we noted Suspension and debarment checks were not performed in accordance with applicable requirements on 3 out of the 6 contracts sampled. Questioned costs: None Context: Using a statistically valid sample, CLA selected 6 covered transactions for testing. 3 of the samples selected did not have a suspension and debarment certification prior to entering in a contract with the vendor. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the Brownsburg Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 002 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).? Condition: During our testing, we noted Suspension and debarment checks were not performed in accordance with applicable requirements on 3 out of the 6 contracts sampled. Questioned costs: None Context: Using a statistically valid sample, CLA selected 6 covered transactions for testing. 3 of the samples selected did not have a suspension and debarment certification prior to entering in a contract with the vendor. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the Brownsburg Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 002 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).? Condition: During our testing, we noted Suspension and debarment checks were not performed in accordance with applicable requirements on 3 out of the 6 contracts sampled. Questioned costs: None Context: Using a statistically valid sample, CLA selected 6 covered transactions for testing. 3 of the samples selected did not have a suspension and debarment certification prior to entering in a contract with the vendor. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the Brownsburg Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Crawfordsville Community School Corporation approval of proper employee suspension and debarment procedure policies, however the verification procedures took place after awarding the vendor?s contract. Questioned costs: None Context: Using a statistically valid sample, CLA selected 5 covered transactions for testing. All had evidence of suspension and debarment checks, however 4 of the 5 checks selected were performed after the contract/agreement date. Of these, all checks were performed within 1 week of the contract date with the exception of 1 selection, which was performed approximately 5 weeks after the contract date. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding and implementation of existing policies caused the Crawfordsville Community School Corporation to be noncompliant with program requirements over procurement, suspension and debarment. Repeat Finding: No. Recommendation: We recommend the Crawfordsville Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Crawfordsville Community School Corporation approval of proper employee suspension and debarment procedure policies, however the verification procedures took place after awarding the vendor?s contract. Questioned costs: None Context: Using a statistically valid sample, CLA selected 5 covered transactions for testing. All had evidence of suspension and debarment checks, however 4 of the 5 checks selected were performed after the contract/agreement date. Of these, all checks were performed within 1 week of the contract date with the exception of 1 selection, which was performed approximately 5 weeks after the contract date. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding and implementation of existing policies caused the Crawfordsville Community School Corporation to be noncompliant with program requirements over procurement, suspension and debarment. Repeat Finding: No. Recommendation: We recommend the Crawfordsville Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Crawfordsville Community School Corporation approval of proper employee suspension and debarment procedure policies, however the verification procedures took place after awarding the vendor?s contract. Questioned costs: None Context: Using a statistically valid sample, CLA selected 5 covered transactions for testing. All had evidence of suspension and debarment checks, however 4 of the 5 checks selected were performed after the contract/agreement date. Of these, all checks were performed within 1 week of the contract date with the exception of 1 selection, which was performed approximately 5 weeks after the contract date. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding and implementation of existing policies caused the Crawfordsville Community School Corporation to be noncompliant with program requirements over procurement, suspension and debarment. Repeat Finding: No. Recommendation: We recommend the Crawfordsville Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Crawfordsville Community School Corporation approval of proper employee suspension and debarment procedure policies, however the verification procedures took place after awarding the vendor?s contract. Questioned costs: None Context: Using a statistically valid sample, CLA selected 5 covered transactions for testing. All had evidence of suspension and debarment checks, however 4 of the 5 checks selected were performed after the contract/agreement date. Of these, all checks were performed within 1 week of the contract date with the exception of 1 selection, which was performed approximately 5 weeks after the contract date. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding and implementation of existing policies caused the Crawfordsville Community School Corporation to be noncompliant with program requirements over procurement, suspension and debarment. Repeat Finding: No. Recommendation: We recommend the Crawfordsville Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Crawfordsville Community School Corporation approval of proper employee suspension and debarment procedure policies, however the verification procedures took place after awarding the vendor?s contract. Questioned costs: None Context: Using a statistically valid sample, CLA selected 5 covered transactions for testing. All had evidence of suspension and debarment checks, however 4 of the 5 checks selected were performed after the contract/agreement date. Of these, all checks were performed within 1 week of the contract date with the exception of 1 selection, which was performed approximately 5 weeks after the contract date. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding and implementation of existing policies caused the Crawfordsville Community School Corporation to be noncompliant with program requirements over procurement, suspension and debarment. Repeat Finding: No. Recommendation: We recommend the Crawfordsville Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Crawfordsville Community School Corporation approval of proper employee suspension and debarment procedure policies, however the verification procedures took place after awarding the vendor?s contract. Questioned costs: None Context: Using a statistically valid sample, CLA selected 5 covered transactions for testing. All had evidence of suspension and debarment checks, however 4 of the 5 checks selected were performed after the contract/agreement date. Of these, all checks were performed within 1 week of the contract date with the exception of 1 selection, which was performed approximately 5 weeks after the contract date. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding and implementation of existing policies caused the Crawfordsville Community School Corporation to be noncompliant with program requirements over procurement, suspension and debarment. Repeat Finding: No. Recommendation: We recommend the Crawfordsville Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Crawfordsville Community School Corporation approval of proper employee suspension and debarment procedure policies, however the verification procedures took place after awarding the vendor?s contract. Questioned costs: None Context: Using a statistically valid sample, CLA selected 5 covered transactions for testing. All had evidence of suspension and debarment checks, however 4 of the 5 checks selected were performed after the contract/agreement date. Of these, all checks were performed within 1 week of the contract date with the exception of 1 selection, which was performed approximately 5 weeks after the contract date. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding and implementation of existing policies caused the Crawfordsville Community School Corporation to be noncompliant with program requirements over procurement, suspension and debarment. Repeat Finding: No. Recommendation: We recommend the Crawfordsville Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Crawfordsville Community School Corporation approval of proper employee suspension and debarment procedure policies, however the verification procedures took place after awarding the vendor?s contract. Questioned costs: None Context: Using a statistically valid sample, CLA selected 5 covered transactions for testing. All had evidence of suspension and debarment checks, however 4 of the 5 checks selected were performed after the contract/agreement date. Of these, all checks were performed within 1 week of the contract date with the exception of 1 selection, which was performed approximately 5 weeks after the contract date. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding and implementation of existing policies caused the Crawfordsville Community School Corporation to be noncompliant with program requirements over procurement, suspension and debarment. Repeat Finding: No. Recommendation: We recommend the Crawfordsville Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Crawfordsville Community School Corporation approval of proper employee suspension and debarment procedure policies, however the verification procedures took place after awarding the vendor?s contract. Questioned costs: None Context: Using a statistically valid sample, CLA selected 5 covered transactions for testing. All had evidence of suspension and debarment checks, however 4 of the 5 checks selected were performed after the contract/agreement date. Of these, all checks were performed within 1 week of the contract date with the exception of 1 selection, which was performed approximately 5 weeks after the contract date. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding and implementation of existing policies caused the Crawfordsville Community School Corporation to be noncompliant with program requirements over procurement, suspension and debarment. Repeat Finding: No. Recommendation: We recommend the Crawfordsville Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? Child Nutrition Cluster Procurement, Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Crawfordsville Community School Corporation approval of proper employee suspension and debarment procedure policies, however the verification procedures took place after awarding the vendor?s contract. Questioned costs: None Context: Using a statistically valid sample, CLA selected 5 covered transactions for testing. All had evidence of suspension and debarment checks, however 4 of the 5 checks selected were performed after the contract/agreement date. Of these, all checks were performed within 1 week of the contract date with the exception of 1 selection, which was performed approximately 5 weeks after the contract date. Cause: Improper understanding and implementation of existing policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding and implementation of existing policies caused the Crawfordsville Community School Corporation to be noncompliant with program requirements over procurement, suspension and debarment. Repeat Finding: No. Recommendation: We recommend the Crawfordsville Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
FINDING 2022-001 SIGNIFICANT DEFICENCY and MATERIAL NONCOMPLIANCE Suspension and Debarment Condition: District did not verify that an entity with which it planned to enter into a covered transaction was not debarred, suspended or otherwise excluded as required by board policy and federal guidelines. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Criteria: Recommended Procedures Cause: During the course of the audit, we determined there exists a high reliance upon key positions of management to operate the procurement process without sufficient third-party review or involvement. Effect: The District entered into a covered transaction with Central Consolidated, Inc. without verifying they were not debarred, suspended or otherwise excluded. Recommendations: The Board of Directors, the Director and key positions of management should re-assess the current board policy and potentially add encompassing compensating controls. The Board should then periodically check that all procedures agreed upon are operational and effective, and adjust procedures as needed. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding. See separate document for planned corrective actions.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
2022 ? 005 ? Child Nutrition Cluster ? Suspension and DebarmentFederal Agency: U.S. Department of EducationFederal Program Title: Child Nutrition ClusterAssistance Listing Number: 10.553/10.555Federal Award Identification Number and Year: FY 21 and FY 22Pass-Through Entity: Indiana Department of EducationPass-Through Entity Number: FY 2021 and FY 2022Award Period: July 1, 2020 through June 30, 2022Type of Finding:? Significant Deficiency in Internal Control over ComplianceCriteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).?Condition: During our testing, we noted Suspension and debarment checks were not performed on the contract sampled. Per the school?s procurement policy, it stated that a certification of suspension and debarment needed to be completed prior to entering into a contract for all contracts over the $25,000 threshold.Questioned costs: NoneContext: Using a statistically valid sample, 1 covered transaction was selected for testing. The Transaction selected did not have a suspension and debarment certification prior to entering in a contract with the vendor.Cause: Improper understanding and implementation of existing policies.Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts.View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 005 ? Child Nutrition Cluster ? Suspension and DebarmentFederal Agency: U.S. Department of EducationFederal Program Title: Child Nutrition ClusterAssistance Listing Number: 10.553/10.555Federal Award Identification Number and Year: FY 21 and FY 22Pass-Through Entity: Indiana Department of EducationPass-Through Entity Number: FY 2021 and FY 2022Award Period: July 1, 2020 through June 30, 2022Type of Finding:? Significant Deficiency in Internal Control over ComplianceCriteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).?Condition: During our testing, we noted Suspension and debarment checks were not performed on the contract sampled. Per the school?s procurement policy, it stated that a certification of suspension and debarment needed to be completed prior to entering into a contract for all contracts over the $25,000 threshold.Questioned costs: NoneContext: Using a statistically valid sample, 1 covered transaction was selected for testing. The Transaction selected did not have a suspension and debarment certification prior to entering in a contract with the vendor.Cause: Improper understanding and implementation of existing policies.Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts.View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 005 ? Child Nutrition Cluster ? Suspension and DebarmentFederal Agency: U.S. Department of EducationFederal Program Title: Child Nutrition ClusterAssistance Listing Number: 10.553/10.555Federal Award Identification Number and Year: FY 21 and FY 22Pass-Through Entity: Indiana Department of EducationPass-Through Entity Number: FY 2021 and FY 2022Award Period: July 1, 2020 through June 30, 2022Type of Finding:? Significant Deficiency in Internal Control over ComplianceCriteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).?Condition: During our testing, we noted Suspension and debarment checks were not performed on the contract sampled. Per the school?s procurement policy, it stated that a certification of suspension and debarment needed to be completed prior to entering into a contract for all contracts over the $25,000 threshold.Questioned costs: NoneContext: Using a statistically valid sample, 1 covered transaction was selected for testing. The Transaction selected did not have a suspension and debarment certification prior to entering in a contract with the vendor.Cause: Improper understanding and implementation of existing policies.Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts.View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 005 ? Child Nutrition Cluster ? Suspension and DebarmentFederal Agency: U.S. Department of EducationFederal Program Title: Child Nutrition ClusterAssistance Listing Number: 10.553/10.555Federal Award Identification Number and Year: FY 21 and FY 22Pass-Through Entity: Indiana Department of EducationPass-Through Entity Number: FY 2021 and FY 2022Award Period: July 1, 2020 through June 30, 2022Type of Finding:? Significant Deficiency in Internal Control over ComplianceCriteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).?Condition: During our testing, we noted Suspension and debarment checks were not performed on the contract sampled. Per the school?s procurement policy, it stated that a certification of suspension and debarment needed to be completed prior to entering into a contract for all contracts over the $25,000 threshold.Questioned costs: NoneContext: Using a statistically valid sample, 1 covered transaction was selected for testing. The Transaction selected did not have a suspension and debarment certification prior to entering in a contract with the vendor.Cause: Improper understanding and implementation of existing policies.Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts.View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 005 ? Child Nutrition Cluster ? Suspension and DebarmentFederal Agency: U.S. Department of EducationFederal Program Title: Child Nutrition ClusterAssistance Listing Number: 10.553/10.555Federal Award Identification Number and Year: FY 21 and FY 22Pass-Through Entity: Indiana Department of EducationPass-Through Entity Number: FY 2021 and FY 2022Award Period: July 1, 2020 through June 30, 2022Type of Finding:? Significant Deficiency in Internal Control over ComplianceCriteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).?Condition: During our testing, we noted Suspension and debarment checks were not performed on the contract sampled. Per the school?s procurement policy, it stated that a certification of suspension and debarment needed to be completed prior to entering into a contract for all contracts over the $25,000 threshold.Questioned costs: NoneContext: Using a statistically valid sample, 1 covered transaction was selected for testing. The Transaction selected did not have a suspension and debarment certification prior to entering in a contract with the vendor.Cause: Improper understanding and implementation of existing policies.Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts.View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 005 ? Child Nutrition Cluster ? Suspension and DebarmentFederal Agency: U.S. Department of EducationFederal Program Title: Child Nutrition ClusterAssistance Listing Number: 10.553/10.555Federal Award Identification Number and Year: FY 21 and FY 22Pass-Through Entity: Indiana Department of EducationPass-Through Entity Number: FY 2021 and FY 2022Award Period: July 1, 2020 through June 30, 2022Type of Finding:? Significant Deficiency in Internal Control over ComplianceCriteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).?Condition: During our testing, we noted Suspension and debarment checks were not performed on the contract sampled. Per the school?s procurement policy, it stated that a certification of suspension and debarment needed to be completed prior to entering into a contract for all contracts over the $25,000 threshold.Questioned costs: NoneContext: Using a statistically valid sample, 1 covered transaction was selected for testing. The Transaction selected did not have a suspension and debarment certification prior to entering in a contract with the vendor.Cause: Improper understanding and implementation of existing policies.Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts.View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
Compliance with Uniform Guidance ? Procurement Suspension and Debarment Information on Federal Program: Unaccompanied Alien Children (Assistance Listing No. 93.676) provided by the Department of Health and Human Services. Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs. Condition: During our testing for procurement compliance, it was determined that the Home did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs. Questioned Cost: None Cause: The Home was not aware of the requirement to review an entity?s status. Effect: The Home is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Home could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs. Perspective Information: Vendors in excess of the $25,000 threshold were reviewed to determine if they are debarred, suspended, or otherwise excluded from participation in federal award programs. None were noted to be ineligible for participation. Repeat Finding: Yes Recommendation: We recommend the Home review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs. Views of the Responsible Officials and Planned Corrective Actions: The Home will revise its procurement policy to include a semi-annual review of the vendors eligible to participate in the federal award programs.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number and Year: WA0000U0T042006 05/25/2021 Pass-Through Agency: Snohomish County Human Services Pass-Through Number(s): HCS-21-50-2039-077, HCS-21-50-2030-077, HCS-21-50-2032-077 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Procedures for verifying that an entity with which an organization plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded must be documented. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6). Condition: Procedures for verifying that an entity with which the Agency entered into covered transaction was not debarred, suspended, or otherwise excluded was not maintained for three out of three transactions tested. Questioned costs: None Context: 3 out of 3 covered transactions tested were not in compliance. Cause: Procedures were followed but not documented. Effect: Appropriate documentation was not maintained as required. Repeat Finding: N/A Recommendation: We recommend that policies and procedures are implemented that appropriate documentation is maintained when entering into transaction with covered entities as defined by 2 CFR section 180.220. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number and Year: WA0000U0T042006 05/25/2021 Pass-Through Agency: Snohomish County Human Services Pass-Through Number(s): HCS-21-50-2039-077, HCS-21-50-2030-077, HCS-21-50-2032-077 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Procedures for verifying that an entity with which an organization plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded must be documented. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6). Condition: Procedures for verifying that an entity with which the Agency entered into covered transaction was not debarred, suspended, or otherwise excluded was not maintained for three out of three transactions tested. Questioned costs: None Context: 3 out of 3 covered transactions tested were not in compliance. Cause: Procedures were followed but not documented. Effect: Appropriate documentation was not maintained as required. Repeat Finding: N/A Recommendation: We recommend that policies and procedures are implemented that appropriate documentation is maintained when entering into transaction with covered entities as defined by 2 CFR section 180.220. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number and Year: WA0000U0T042006 05/25/2021 Pass-Through Agency: Snohomish County Human Services Pass-Through Number(s): HCS-21-50-2039-077, HCS-21-50-2030-077, HCS-21-50-2032-077 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Procedures for verifying that an entity with which an organization plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded must be documented. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6). Condition: Procedures for verifying that an entity with which the Agency entered into covered transaction was not debarred, suspended, or otherwise excluded was not maintained for three out of three transactions tested. Questioned costs: None Context: 3 out of 3 covered transactions tested were not in compliance. Cause: Procedures were followed but not documented. Effect: Appropriate documentation was not maintained as required. Repeat Finding: N/A Recommendation: We recommend that policies and procedures are implemented that appropriate documentation is maintained when entering into transaction with covered entities as defined by 2 CFR section 180.220. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Procurement Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Numbers: 84.425F Award Period: July 1, 2021 through June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or specific requirement: The Code of Federal Regulations section 215.44 states written selection procedures require solicitations for goods or services incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured, identify all requirements for the material, product, or service to be procured, identify all requirements that the offerors must fulfill, and include all other factors to be used in evaluating bids or proposals. In addition, per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: During our testing, we noted the College did not have properly documented procurement regulations that met the federal requirements. We were unable to verify any procurement methods used for the vendor tested. In addition, during our testing, we noted for one out of the one vendors over $25,000 tested, there was not documented suspension and debarment procedures. Questioned costs: None Context: The College did not have documented procurement procedures or procedures in place to verify vendors had not been suspended or debarred. They were not following procurement requirements under Uniform Guidance. Cause: The College was not aware of the requirements of the Uniform Guidance. Effect: The lack of documented procurement regulations and policies over these compliance requirements provides an opportunity for noncompliance. In addition, the College could enter into a covered transaction with a vendor who is suspended or debarred. Repeat Finding: No Recommendation: We recommend the College document suspension and debarment procedures going forward for any vendors with federal expenditures over $25,000. We also recommend a procurement policy be implemented that meets the requirements of Uniform Guidance as well as the conflict of interest policy is updated to conform with Uniform Guidance. Lastly, we recommend documentation be retained as it relates to the methodology chosen for procurement in accordance with the procurement policy. Views of responsible officials: There is no disagreement with the audit finding.