Reporting a determination that an applicant is not qualified for a Federal award.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program, COVID-19 School Breakfast Program, and COVID-19 Summer School Food Service Program CFDA No. 10.553, 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District?s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program, COVID-19 School Breakfast Program, and COVID-19 Summer School Food Service Program CFDA No. 10.553, 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District?s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program, COVID-19 School Breakfast Program, and COVID-19 Summer School Food Service Program CFDA No. 10.553, 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District?s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program, COVID-19 School Breakfast Program, and COVID-19 Summer School Food Service Program CFDA No. 10.553, 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District?s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.
Program: CFDA 84.282 ? Charter Schools Sponsor Award Number: 0089-21-1044 Sponsor Agency: New York State Education Department Criteria: Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing executive orders and 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Citation: 2 CFR 200.213 Condition: ICS has a formal policy in place to evaluate contracts with vendors that are considered covered under 2 CFR 180.200 to ensure that the recipients of federal funding was not suspended or debarred, however, this policy was not followed, and documentation to support management?s determination was not maintained for all applicable vendors. Cause: ICS did not follow the suspension and debarment policies in place. Effect: There is a risk that vendors who are suspended or debarred will receive federal funds through payment on their contract with ICS. Questioned Costs: None. There were no instances of non-compliance noted. Context: Management did not have formal documentation for 7 of 32 applicable vendors regarding whether procedures were performed to determine if the vendors selected have been suspended or debarred. Repeat Finding: Yes Recommendation: We recommend that management follows their written procedures and maintain supporting documentation for evaluating vendors to ensure they have not been suspended or debarred. Views of Responsible Officials: See Corrective Action Plan attached.
Reference Number: 2022-002 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listing Number: 10.760 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work to individuals and firms or economic considerations. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for three out of five vendors was not documented. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: The County did not establish effective internal controls over suspension and debarment transactions Effect: The County is not in compliance with federal suspension and debarment regulations. Recommendation: The County should ensure they maintain supporting documentation to support their review of suspension and debarment status.
Reference Number: 2022-002 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listing Number: 10.760 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work to individuals and firms or economic considerations. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for three out of five vendors was not documented. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: The County did not establish effective internal controls over suspension and debarment transactions Effect: The County is not in compliance with federal suspension and debarment regulations. Recommendation: The County should ensure they maintain supporting documentation to support their review of suspension and debarment status.
Reference Number: 2022-002 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listing Number: 10.760 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work to individuals and firms or economic considerations. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for three out of five vendors was not documented. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: The County did not establish effective internal controls over suspension and debarment transactions Effect: The County is not in compliance with federal suspension and debarment regulations. Recommendation: The County should ensure they maintain supporting documentation to support their review of suspension and debarment status.
Criteria or specific requirement: Per 2 CFR section 200.320. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Per 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: Documentation was not maintained to support why vendors were selected using noncompetitive procurement. Furthermore, the documentation to support the vendor?s suspension debarment status was not provided. Questioned costs: None Context: For 5 of 7 procurement transactions greater than $10,000, no documentation was provided to justify noncompetitive procurement method used. 3 of the 7 vendors exceeded $25,000 in procurement and further were not reviewed to ensure the vendors were not suspended or disbarred. Cause: The College used vendors that have been historically used by the institution during non-pandemic periods of time to acquire needed supplies and materials for the suppression and monitoring of COVID where possible. Several purchases that were needed for these efforts were not available from the College?s normal vendors and those costs had to be acquired from new sources. Multiple sources were investigated, but with supply chain issues, the College was unable to always find multiple vendors that could meet the needs of the institution. With changes in staffing at the institution, the records related to the processes used and vendor?s investigated have not been retained. The vendor?s used have all subsequently been checked for suspension debarment status and none where found to have any issues. Effect: Vendors may be selected in a manner that is not consistent with Federal guidelines and Federal funds may be paid to parties that are ineligible to participate in a Federal program. Repeat Finding: No Recommendation: We recommend the College establish policies and procedures to properly identify procured transactions and maintain documentation to support performance of the procurement procedures. We also recommend the College evaluate its policies procedures to ensure that suspension and debarment requirements are being met prior to entering into transactions with vendors. Views of responsible officials: There is no disagreement with the audit finding.
COVID-19 Child Nutrition - Procurement Information on Federal Program: Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, Summer Food Service Program for Children, and Food Distribution (Assistance Listing No. 10.553, Assistance Listing No. 10.555 and Assistance Listing No. 10.559) passed through New York State Education Department. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our testing, we noted that the District is not documenting the annual verification of the eligibility of vendors to participate in Federal assistance programs. Questioned Cost: None. Cause: The District did not maintain documentation as to the consideration and annual review of a vendor?s eligibility to participate in Federal assistance programs. Effect: The District is not in compliance with 2 CFR Section 200.213. As a result vendors that are not eligible for participation in Federal assistance programs or activities could be paid with federal dollars or the District could be overpaying for goods and services. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that an annual review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to engaging in and disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review and update procedures to document this review. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
COVID-19 Child Nutrition - Procurement Information on Federal Program: Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, Summer Food Service Program for Children, and Food Distribution (Assistance Listing No. 10.553, Assistance Listing No. 10.555 and Assistance Listing No. 10.559) passed through New York State Education Department. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our testing, we noted that the District is not documenting the annual verification of the eligibility of vendors to participate in Federal assistance programs. Questioned Cost: None. Cause: The District did not maintain documentation as to the consideration and annual review of a vendor?s eligibility to participate in Federal assistance programs. Effect: The District is not in compliance with 2 CFR Section 200.213. As a result vendors that are not eligible for participation in Federal assistance programs or activities could be paid with federal dollars or the District could be overpaying for goods and services. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that an annual review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to engaging in and disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review and update procedures to document this review. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
COVID-19 Child Nutrition - Procurement Information on Federal Program: Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, Summer Food Service Program for Children, and Food Distribution (Assistance Listing No. 10.553, Assistance Listing No. 10.555 and Assistance Listing No. 10.559) passed through New York State Education Department. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our testing, we noted that the District is not documenting the annual verification of the eligibility of vendors to participate in Federal assistance programs. Questioned Cost: None. Cause: The District did not maintain documentation as to the consideration and annual review of a vendor?s eligibility to participate in Federal assistance programs. Effect: The District is not in compliance with 2 CFR Section 200.213. As a result vendors that are not eligible for participation in Federal assistance programs or activities could be paid with federal dollars or the District could be overpaying for goods and services. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that an annual review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to engaging in and disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review and update procedures to document this review. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
COVID-19 Child Nutrition - Procurement Information on Federal Program: Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, Summer Food Service Program for Children, and Food Distribution (Assistance Listing No. 10.553, Assistance Listing No. 10.555 and Assistance Listing No. 10.559) passed through New York State Education Department. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our testing, we noted that the District is not documenting the annual verification of the eligibility of vendors to participate in Federal assistance programs. Questioned Cost: None. Cause: The District did not maintain documentation as to the consideration and annual review of a vendor?s eligibility to participate in Federal assistance programs. Effect: The District is not in compliance with 2 CFR Section 200.213. As a result vendors that are not eligible for participation in Federal assistance programs or activities could be paid with federal dollars or the District could be overpaying for goods and services. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that an annual review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to engaging in and disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review and update procedures to document this review. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
2022-002: DOCUMENTATION OF PROCUREMENT, SUSPENSION, AND DEBARMENT PROCEDURES (CODE 50000) Programs Affected ESEA: Title I School Improvement Grant, U.S. Department of Education, Federal Assistance Listing Number 84.377, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER II), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER III) 80%, U.S. Department of Education, Federal Assistance Listing Number 84.425U, passed through California Department of Education, award year 2021/22, award number not available. Governor's Emergency Education Relief (GEER), U.S. Department of Education, Federal Assistance Listing Number 84.425C, passed through California Department of Education, award year 2021/22, award number not available. National School Lunch Program, U.S. Department of Agriculture, Federal Assistance Listing Number 10.555, passed through the California Department of Education, award year 2021/22, award number not available. ESEA: Title I, U.S. Department of Education, Federal Assistance Listing Number 84.010, passed through California Department of Education, award year 2021/22, award number not available. ESEA: Title IV, Part A, Student Support and Academic Enrichment, U.S. Department of Education, Federal Assistance Listing Number 84.424, passed through California Department of Education, award year 2021/22, award number not available. Criteria Title 2, Section 200.318 (2 CFR 200.318) of the Code of Federal Regulations (CFR), requires written policies and procedures regarding procurement of goods and services for federal awards. 2 CFR 200.320 requires that one of three procurement methods be used: Procurements by micro-purchases for acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (currently $10,000); Procurements by small purchase procedures, for securing goods or services that do not cost more than the Simplified Acquisition Threshold (currently $250,000); or Procurement by sealed bids, for goods and services in excess of the Simplified Acquisition Threshold. In addition, 2 CFR 200.213 requires that written procedures be in place for checking suspension and debarment status of certain vendors receiving federal funds from the District. Condition During our testing of expenditures, in which we tested 37 percent of all federal expenditures for goods and services, we noted that the District did not document procurement procedures and vendor suspension/debarment review for purchases charged to federal programs. Based on discussions with District management, they did perform procurement procedures regarding review of vendors for reasonable and best available pricing and for suspension and debarment, but these procedures were not documented in writing. None of the District's expenditures exceeded the Simplified Acquisition Threshold. No unallowable costs were noted as a result of this finding, and based on our review of vendors used for federal program expenditures, none of the vendors receiving federal funds were suspended or debarred in 2021/22. Identification of Repeat Finding This finding is a repeat of prior year Finding 2021-002. Cause The District did establish a form to document in writing the procurement and suspension and debarment procedures performed for vendors during the year, but did not implement the use of that form in 2021/22. Effect Based on review of detail of federal expenditures, there were no vendors or contractors who exceeded the Simplified Acquisition Threshold, and based on audit testing of significant vendors used by the District during the year, no vendors or contractors were noted who were suspended or debarred, and no unallowed expenditures were noted. Questioned Costs There are no questioned costs. However, the District did not document that it utilized the lowest cost vendor possible. The District has limited options available for vendors charged to its federal programs and it is unlikely that a reliable lower cost vendor would be found. Recommendation We recommend that the District implement the use of the form they have created to document review of multiple vendor quotes for services and for verifying that vendors are not suspended or debarred from receiving federal funds. We further recommend that the District update its procurement policy to include all federal programs. Views of Responsible Officials and Planned Corrective Actions The District agrees and will adhere to the corrective action plan described in the "District's Corrective Action Plan" section immediately following this section of the audit report.
2022-002: DOCUMENTATION OF PROCUREMENT, SUSPENSION, AND DEBARMENT PROCEDURES (CODE 50000) Programs Affected ESEA: Title I School Improvement Grant, U.S. Department of Education, Federal Assistance Listing Number 84.377, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER II), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER III) 80%, U.S. Department of Education, Federal Assistance Listing Number 84.425U, passed through California Department of Education, award year 2021/22, award number not available. Governor's Emergency Education Relief (GEER), U.S. Department of Education, Federal Assistance Listing Number 84.425C, passed through California Department of Education, award year 2021/22, award number not available. National School Lunch Program, U.S. Department of Agriculture, Federal Assistance Listing Number 10.555, passed through the California Department of Education, award year 2021/22, award number not available. ESEA: Title I, U.S. Department of Education, Federal Assistance Listing Number 84.010, passed through California Department of Education, award year 2021/22, award number not available. ESEA: Title IV, Part A, Student Support and Academic Enrichment, U.S. Department of Education, Federal Assistance Listing Number 84.424, passed through California Department of Education, award year 2021/22, award number not available. Criteria Title 2, Section 200.318 (2 CFR 200.318) of the Code of Federal Regulations (CFR), requires written policies and procedures regarding procurement of goods and services for federal awards. 2 CFR 200.320 requires that one of three procurement methods be used: Procurements by micro-purchases for acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (currently $10,000); Procurements by small purchase procedures, for securing goods or services that do not cost more than the Simplified Acquisition Threshold (currently $250,000); or Procurement by sealed bids, for goods and services in excess of the Simplified Acquisition Threshold. In addition, 2 CFR 200.213 requires that written procedures be in place for checking suspension and debarment status of certain vendors receiving federal funds from the District. Condition During our testing of expenditures, in which we tested 37 percent of all federal expenditures for goods and services, we noted that the District did not document procurement procedures and vendor suspension/debarment review for purchases charged to federal programs. Based on discussions with District management, they did perform procurement procedures regarding review of vendors for reasonable and best available pricing and for suspension and debarment, but these procedures were not documented in writing. None of the District's expenditures exceeded the Simplified Acquisition Threshold. No unallowable costs were noted as a result of this finding, and based on our review of vendors used for federal program expenditures, none of the vendors receiving federal funds were suspended or debarred in 2021/22. Identification of Repeat Finding This finding is a repeat of prior year Finding 2021-002. Cause The District did establish a form to document in writing the procurement and suspension and debarment procedures performed for vendors during the year, but did not implement the use of that form in 2021/22. Effect Based on review of detail of federal expenditures, there were no vendors or contractors who exceeded the Simplified Acquisition Threshold, and based on audit testing of significant vendors used by the District during the year, no vendors or contractors were noted who were suspended or debarred, and no unallowed expenditures were noted. Questioned Costs There are no questioned costs. However, the District did not document that it utilized the lowest cost vendor possible. The District has limited options available for vendors charged to its federal programs and it is unlikely that a reliable lower cost vendor would be found. Recommendation We recommend that the District implement the use of the form they have created to document review of multiple vendor quotes for services and for verifying that vendors are not suspended or debarred from receiving federal funds. We further recommend that the District update its procurement policy to include all federal programs. Views of Responsible Officials and Planned Corrective Actions The District agrees and will adhere to the corrective action plan described in the "District's Corrective Action Plan" section immediately following this section of the audit report.
2022-002: DOCUMENTATION OF PROCUREMENT, SUSPENSION, AND DEBARMENT PROCEDURES (CODE 50000) Programs Affected ESEA: Title I School Improvement Grant, U.S. Department of Education, Federal Assistance Listing Number 84.377, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER II), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER III) 80%, U.S. Department of Education, Federal Assistance Listing Number 84.425U, passed through California Department of Education, award year 2021/22, award number not available. Governor's Emergency Education Relief (GEER), U.S. Department of Education, Federal Assistance Listing Number 84.425C, passed through California Department of Education, award year 2021/22, award number not available. National School Lunch Program, U.S. Department of Agriculture, Federal Assistance Listing Number 10.555, passed through the California Department of Education, award year 2021/22, award number not available. ESEA: Title I, U.S. Department of Education, Federal Assistance Listing Number 84.010, passed through California Department of Education, award year 2021/22, award number not available. ESEA: Title IV, Part A, Student Support and Academic Enrichment, U.S. Department of Education, Federal Assistance Listing Number 84.424, passed through California Department of Education, award year 2021/22, award number not available. Criteria Title 2, Section 200.318 (2 CFR 200.318) of the Code of Federal Regulations (CFR), requires written policies and procedures regarding procurement of goods and services for federal awards. 2 CFR 200.320 requires that one of three procurement methods be used: Procurements by micro-purchases for acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (currently $10,000); Procurements by small purchase procedures, for securing goods or services that do not cost more than the Simplified Acquisition Threshold (currently $250,000); or Procurement by sealed bids, for goods and services in excess of the Simplified Acquisition Threshold. In addition, 2 CFR 200.213 requires that written procedures be in place for checking suspension and debarment status of certain vendors receiving federal funds from the District. Condition During our testing of expenditures, in which we tested 37 percent of all federal expenditures for goods and services, we noted that the District did not document procurement procedures and vendor suspension/debarment review for purchases charged to federal programs. Based on discussions with District management, they did perform procurement procedures regarding review of vendors for reasonable and best available pricing and for suspension and debarment, but these procedures were not documented in writing. None of the District's expenditures exceeded the Simplified Acquisition Threshold. No unallowable costs were noted as a result of this finding, and based on our review of vendors used for federal program expenditures, none of the vendors receiving federal funds were suspended or debarred in 2021/22. Identification of Repeat Finding This finding is a repeat of prior year Finding 2021-002. Cause The District did establish a form to document in writing the procurement and suspension and debarment procedures performed for vendors during the year, but did not implement the use of that form in 2021/22. Effect Based on review of detail of federal expenditures, there were no vendors or contractors who exceeded the Simplified Acquisition Threshold, and based on audit testing of significant vendors used by the District during the year, no vendors or contractors were noted who were suspended or debarred, and no unallowed expenditures were noted. Questioned Costs There are no questioned costs. However, the District did not document that it utilized the lowest cost vendor possible. The District has limited options available for vendors charged to its federal programs and it is unlikely that a reliable lower cost vendor would be found. Recommendation We recommend that the District implement the use of the form they have created to document review of multiple vendor quotes for services and for verifying that vendors are not suspended or debarred from receiving federal funds. We further recommend that the District update its procurement policy to include all federal programs. Views of Responsible Officials and Planned Corrective Actions The District agrees and will adhere to the corrective action plan described in the "District's Corrective Action Plan" section immediately following this section of the audit report.
2022-002: DOCUMENTATION OF PROCUREMENT, SUSPENSION, AND DEBARMENT PROCEDURES (CODE 50000) Programs Affected ESEA: Title I School Improvement Grant, U.S. Department of Education, Federal Assistance Listing Number 84.377, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER II), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER III) 80%, U.S. Department of Education, Federal Assistance Listing Number 84.425U, passed through California Department of Education, award year 2021/22, award number not available. Governor's Emergency Education Relief (GEER), U.S. Department of Education, Federal Assistance Listing Number 84.425C, passed through California Department of Education, award year 2021/22, award number not available. National School Lunch Program, U.S. Department of Agriculture, Federal Assistance Listing Number 10.555, passed through the California Department of Education, award year 2021/22, award number not available. ESEA: Title I, U.S. Department of Education, Federal Assistance Listing Number 84.010, passed through California Department of Education, award year 2021/22, award number not available. ESEA: Title IV, Part A, Student Support and Academic Enrichment, U.S. Department of Education, Federal Assistance Listing Number 84.424, passed through California Department of Education, award year 2021/22, award number not available. Criteria Title 2, Section 200.318 (2 CFR 200.318) of the Code of Federal Regulations (CFR), requires written policies and procedures regarding procurement of goods and services for federal awards. 2 CFR 200.320 requires that one of three procurement methods be used: Procurements by micro-purchases for acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (currently $10,000); Procurements by small purchase procedures, for securing goods or services that do not cost more than the Simplified Acquisition Threshold (currently $250,000); or Procurement by sealed bids, for goods and services in excess of the Simplified Acquisition Threshold. In addition, 2 CFR 200.213 requires that written procedures be in place for checking suspension and debarment status of certain vendors receiving federal funds from the District. Condition During our testing of expenditures, in which we tested 37 percent of all federal expenditures for goods and services, we noted that the District did not document procurement procedures and vendor suspension/debarment review for purchases charged to federal programs. Based on discussions with District management, they did perform procurement procedures regarding review of vendors for reasonable and best available pricing and for suspension and debarment, but these procedures were not documented in writing. None of the District's expenditures exceeded the Simplified Acquisition Threshold. No unallowable costs were noted as a result of this finding, and based on our review of vendors used for federal program expenditures, none of the vendors receiving federal funds were suspended or debarred in 2021/22. Identification of Repeat Finding This finding is a repeat of prior year Finding 2021-002. Cause The District did establish a form to document in writing the procurement and suspension and debarment procedures performed for vendors during the year, but did not implement the use of that form in 2021/22. Effect Based on review of detail of federal expenditures, there were no vendors or contractors who exceeded the Simplified Acquisition Threshold, and based on audit testing of significant vendors used by the District during the year, no vendors or contractors were noted who were suspended or debarred, and no unallowed expenditures were noted. Questioned Costs There are no questioned costs. However, the District did not document that it utilized the lowest cost vendor possible. The District has limited options available for vendors charged to its federal programs and it is unlikely that a reliable lower cost vendor would be found. Recommendation We recommend that the District implement the use of the form they have created to document review of multiple vendor quotes for services and for verifying that vendors are not suspended or debarred from receiving federal funds. We further recommend that the District update its procurement policy to include all federal programs. Views of Responsible Officials and Planned Corrective Actions The District agrees and will adhere to the corrective action plan described in the "District's Corrective Action Plan" section immediately following this section of the audit report.
2022-002: DOCUMENTATION OF PROCUREMENT, SUSPENSION, AND DEBARMENT PROCEDURES (CODE 50000) Programs Affected ESEA: Title I School Improvement Grant, U.S. Department of Education, Federal Assistance Listing Number 84.377, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER II), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER III) 80%, U.S. Department of Education, Federal Assistance Listing Number 84.425U, passed through California Department of Education, award year 2021/22, award number not available. Governor's Emergency Education Relief (GEER), U.S. Department of Education, Federal Assistance Listing Number 84.425C, passed through California Department of Education, award year 2021/22, award number not available. National School Lunch Program, U.S. Department of Agriculture, Federal Assistance Listing Number 10.555, passed through the California Department of Education, award year 2021/22, award number not available. ESEA: Title I, U.S. Department of Education, Federal Assistance Listing Number 84.010, passed through California Department of Education, award year 2021/22, award number not available. ESEA: Title IV, Part A, Student Support and Academic Enrichment, U.S. Department of Education, Federal Assistance Listing Number 84.424, passed through California Department of Education, award year 2021/22, award number not available. Criteria Title 2, Section 200.318 (2 CFR 200.318) of the Code of Federal Regulations (CFR), requires written policies and procedures regarding procurement of goods and services for federal awards. 2 CFR 200.320 requires that one of three procurement methods be used: Procurements by micro-purchases for acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (currently $10,000); Procurements by small purchase procedures, for securing goods or services that do not cost more than the Simplified Acquisition Threshold (currently $250,000); or Procurement by sealed bids, for goods and services in excess of the Simplified Acquisition Threshold. In addition, 2 CFR 200.213 requires that written procedures be in place for checking suspension and debarment status of certain vendors receiving federal funds from the District. Condition During our testing of expenditures, in which we tested 37 percent of all federal expenditures for goods and services, we noted that the District did not document procurement procedures and vendor suspension/debarment review for purchases charged to federal programs. Based on discussions with District management, they did perform procurement procedures regarding review of vendors for reasonable and best available pricing and for suspension and debarment, but these procedures were not documented in writing. None of the District's expenditures exceeded the Simplified Acquisition Threshold. No unallowable costs were noted as a result of this finding, and based on our review of vendors used for federal program expenditures, none of the vendors receiving federal funds were suspended or debarred in 2021/22. Identification of Repeat Finding This finding is a repeat of prior year Finding 2021-002. Cause The District did establish a form to document in writing the procurement and suspension and debarment procedures performed for vendors during the year, but did not implement the use of that form in 2021/22. Effect Based on review of detail of federal expenditures, there were no vendors or contractors who exceeded the Simplified Acquisition Threshold, and based on audit testing of significant vendors used by the District during the year, no vendors or contractors were noted who were suspended or debarred, and no unallowed expenditures were noted. Questioned Costs There are no questioned costs. However, the District did not document that it utilized the lowest cost vendor possible. The District has limited options available for vendors charged to its federal programs and it is unlikely that a reliable lower cost vendor would be found. Recommendation We recommend that the District implement the use of the form they have created to document review of multiple vendor quotes for services and for verifying that vendors are not suspended or debarred from receiving federal funds. We further recommend that the District update its procurement policy to include all federal programs. Views of Responsible Officials and Planned Corrective Actions The District agrees and will adhere to the corrective action plan described in the "District's Corrective Action Plan" section immediately following this section of the audit report.
2022-002: DOCUMENTATION OF PROCUREMENT, SUSPENSION, AND DEBARMENT PROCEDURES (CODE 50000) Programs Affected ESEA: Title I School Improvement Grant, U.S. Department of Education, Federal Assistance Listing Number 84.377, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER II), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER III) 80%, U.S. Department of Education, Federal Assistance Listing Number 84.425U, passed through California Department of Education, award year 2021/22, award number not available. Governor's Emergency Education Relief (GEER), U.S. Department of Education, Federal Assistance Listing Number 84.425C, passed through California Department of Education, award year 2021/22, award number not available. National School Lunch Program, U.S. Department of Agriculture, Federal Assistance Listing Number 10.555, passed through the California Department of Education, award year 2021/22, award number not available. ESEA: Title I, U.S. Department of Education, Federal Assistance Listing Number 84.010, passed through California Department of Education, award year 2021/22, award number not available. ESEA: Title IV, Part A, Student Support and Academic Enrichment, U.S. Department of Education, Federal Assistance Listing Number 84.424, passed through California Department of Education, award year 2021/22, award number not available. Criteria Title 2, Section 200.318 (2 CFR 200.318) of the Code of Federal Regulations (CFR), requires written policies and procedures regarding procurement of goods and services for federal awards. 2 CFR 200.320 requires that one of three procurement methods be used: Procurements by micro-purchases for acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (currently $10,000); Procurements by small purchase procedures, for securing goods or services that do not cost more than the Simplified Acquisition Threshold (currently $250,000); or Procurement by sealed bids, for goods and services in excess of the Simplified Acquisition Threshold. In addition, 2 CFR 200.213 requires that written procedures be in place for checking suspension and debarment status of certain vendors receiving federal funds from the District. Condition During our testing of expenditures, in which we tested 37 percent of all federal expenditures for goods and services, we noted that the District did not document procurement procedures and vendor suspension/debarment review for purchases charged to federal programs. Based on discussions with District management, they did perform procurement procedures regarding review of vendors for reasonable and best available pricing and for suspension and debarment, but these procedures were not documented in writing. None of the District's expenditures exceeded the Simplified Acquisition Threshold. No unallowable costs were noted as a result of this finding, and based on our review of vendors used for federal program expenditures, none of the vendors receiving federal funds were suspended or debarred in 2021/22. Identification of Repeat Finding This finding is a repeat of prior year Finding 2021-002. Cause The District did establish a form to document in writing the procurement and suspension and debarment procedures performed for vendors during the year, but did not implement the use of that form in 2021/22. Effect Based on review of detail of federal expenditures, there were no vendors or contractors who exceeded the Simplified Acquisition Threshold, and based on audit testing of significant vendors used by the District during the year, no vendors or contractors were noted who were suspended or debarred, and no unallowed expenditures were noted. Questioned Costs There are no questioned costs. However, the District did not document that it utilized the lowest cost vendor possible. The District has limited options available for vendors charged to its federal programs and it is unlikely that a reliable lower cost vendor would be found. Recommendation We recommend that the District implement the use of the form they have created to document review of multiple vendor quotes for services and for verifying that vendors are not suspended or debarred from receiving federal funds. We further recommend that the District update its procurement policy to include all federal programs. Views of Responsible Officials and Planned Corrective Actions The District agrees and will adhere to the corrective action plan described in the "District's Corrective Action Plan" section immediately following this section of the audit report.
2022-002: DOCUMENTATION OF PROCUREMENT, SUSPENSION, AND DEBARMENT PROCEDURES (CODE 50000) Programs Affected ESEA: Title I School Improvement Grant, U.S. Department of Education, Federal Assistance Listing Number 84.377, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER II), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER III) 80%, U.S. Department of Education, Federal Assistance Listing Number 84.425U, passed through California Department of Education, award year 2021/22, award number not available. Governor's Emergency Education Relief (GEER), U.S. Department of Education, Federal Assistance Listing Number 84.425C, passed through California Department of Education, award year 2021/22, award number not available. National School Lunch Program, U.S. Department of Agriculture, Federal Assistance Listing Number 10.555, passed through the California Department of Education, award year 2021/22, award number not available. ESEA: Title I, U.S. Department of Education, Federal Assistance Listing Number 84.010, passed through California Department of Education, award year 2021/22, award number not available. ESEA: Title IV, Part A, Student Support and Academic Enrichment, U.S. Department of Education, Federal Assistance Listing Number 84.424, passed through California Department of Education, award year 2021/22, award number not available. Criteria Title 2, Section 200.318 (2 CFR 200.318) of the Code of Federal Regulations (CFR), requires written policies and procedures regarding procurement of goods and services for federal awards. 2 CFR 200.320 requires that one of three procurement methods be used: Procurements by micro-purchases for acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (currently $10,000); Procurements by small purchase procedures, for securing goods or services that do not cost more than the Simplified Acquisition Threshold (currently $250,000); or Procurement by sealed bids, for goods and services in excess of the Simplified Acquisition Threshold. In addition, 2 CFR 200.213 requires that written procedures be in place for checking suspension and debarment status of certain vendors receiving federal funds from the District. Condition During our testing of expenditures, in which we tested 37 percent of all federal expenditures for goods and services, we noted that the District did not document procurement procedures and vendor suspension/debarment review for purchases charged to federal programs. Based on discussions with District management, they did perform procurement procedures regarding review of vendors for reasonable and best available pricing and for suspension and debarment, but these procedures were not documented in writing. None of the District's expenditures exceeded the Simplified Acquisition Threshold. No unallowable costs were noted as a result of this finding, and based on our review of vendors used for federal program expenditures, none of the vendors receiving federal funds were suspended or debarred in 2021/22. Identification of Repeat Finding This finding is a repeat of prior year Finding 2021-002. Cause The District did establish a form to document in writing the procurement and suspension and debarment procedures performed for vendors during the year, but did not implement the use of that form in 2021/22. Effect Based on review of detail of federal expenditures, there were no vendors or contractors who exceeded the Simplified Acquisition Threshold, and based on audit testing of significant vendors used by the District during the year, no vendors or contractors were noted who were suspended or debarred, and no unallowed expenditures were noted. Questioned Costs There are no questioned costs. However, the District did not document that it utilized the lowest cost vendor possible. The District has limited options available for vendors charged to its federal programs and it is unlikely that a reliable lower cost vendor would be found. Recommendation We recommend that the District implement the use of the form they have created to document review of multiple vendor quotes for services and for verifying that vendors are not suspended or debarred from receiving federal funds. We further recommend that the District update its procurement policy to include all federal programs. Views of Responsible Officials and Planned Corrective Actions The District agrees and will adhere to the corrective action plan described in the "District's Corrective Action Plan" section immediately following this section of the audit report.
FINDING 2022-002 ? NON-COMPLIANCE AND LIMITED CONTROLS OVER SUSPENSION AND DEBARMENT Criteria ? In accordance with 2 CFR 200.213 and 2 CFR part 180 non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred, or otherwise excluded. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. The requirement is for non-federal entities to check for suspended and debarred entities and persons, or obtain certifications before entering covered transactions. In addition, 2 CFR 200.303 requires that ?The non-Federal entity must: (a)?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Condition ? The Center has adopted a federal suspension and debarment policy that requires contractors with awards that exceed the Center?s small purchase threshold to provide certifications regarding their exclusion status and that of their principal officers. During our testing we were not provided copies of obtained certifications, or proof that the Center has checked on SAM.gov whether the covered contractors have been suspended, or debarred prior to entering into the covered transactions. Questioned Costs ? None, as management subsequently searched on SAM.gov and demonstrated that none of the tested contractors in covered transactions had been suspended or debarred. Effect ? The Center did not perform proper suspension and debarment procedures regarding certain vendors of covered transaction prior to obtaining their services. This could have resulted in disallowed costs by the federal grantor. Cause ? The Center has not implemented their written policy, procedures or controls to ensure compliance with the federal suspension and debarment requirements. Recommendation ? We recommend that the Center consider changing its policy to allow for checking for suspended or debarred persons or entities on SAM.gov, in addition to allowing a contractor certification as a substitute, and implement its policy by establishing procedures and internal controls to ensure that the Uniform Guidance suspension and debarment requirements are met prior to entering into each covered transaction. Views of Responsible Officials ? We agree with the auditors? finding and the accompanying recommendation that the Center implements its policy with procedures and internal controls to ensure that the Uniform Guidance suspension and debarment requirements are met.
Finding 2022-006: Suspension and Debarment and U.S. Government Regulations on Terrorism Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: CFR 200.213 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Additionally, as outlined in each Department of State award, recipients of U.S. Government funds must adhere to the United States Government’s requirements on screening all potential vendors, suppliers, sub-contractors/grantees and employees against the United States Department of State’s Terrorism watch list. The screening of all potential vendors, suppliers, subcontractors/ grantees and employees must be documented in writing. Condition: Astraea did not provide documentation to support its screenings for its potential and current vendors, suppliers, contractors, employees, etc. that were paid with Federal funds. Cause: Astraea did not have a procedure in place to ensure all required screenings are performed and documentation to support the screening is maintained. Context: During our audit, we inquired of evidence of such a process, and Astraea was unable to provide support with respect to this area. It should be noted, that Astraea did perform and document the required screenings in January 2023 (in response to the finding issued during the fiscal year 2021 audit finding). Effect: Astraea could make payments to an entity or individual that has been debarred or suspended by the US Government; such costs would be disallowed, and Astraea could face consequences for lack of compliance. Questioned Costs: None noted. Identification as a Repeat Finding: Yes - Finding 2021-007. Recommendation: We recommend Astraea develop a policy of how screenings will be performed and how documentation will be maintained in order to demonstrate compliance with government regulations. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the four vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes (Finding 2021-001) Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the four vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes (Finding 2021-001) Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the four vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes (Finding 2021-001) Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Criteria: Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance: Per 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: the County did not maintain documentation of a vendor’s suspension and debarment status. Cause: the County’s Procurement office was unaware of the suspension and debarment verification requirement for all federally funded procurements and subawards $25,000 or more. Questioned Costs: None Effect: Federal funds may be paid to parties that are ineligible to participate in a federal program. Recommendation: We recommend the County evaluate its policies procedures to ensure that suspension and debarment requirements are being met prior to entering into transactions with vendors. Identification of Repeat Finding: This is a first year finding. Views of Responsible Officials: management agrees with the finding.
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 2022 Award Period: Fiscal Year 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Condition The Town does not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred. Questioned Costs None Context Although the Town does not have policies or procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred, we did not identify instances where Federal grant awards were paid to suspended or debarred vendors for 3 of 3 suspension and debarment transactions selected for testing. Cause Management was not aware of the requirements of 2 CFR section 180 within Uniform Guidance. Effect The Town is at risk for noncompliance with federal grants as it relates to suspension and debarment. Repeat Finding No Recommendation We recommend that the Town implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them ford goods or services. Views of Responsible Officials Management agrees with this finding.
2021-001 - Procurement, Suspension and Debarment (Significant Deficiency) Condition: During our testwork over procurement, we noted that there were no procurement policy and payments made to vendors before checking suspension or debarment status on www.sam.gov. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: §200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: DSAL did not establish adequate internal controls and procedures and procurement policy to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: DSAL is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require DSAL to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that DSAL establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: Management agrees with the findings and has provided the accompanying corrective action plan. Estimated Completion Date: November 20, 2022 Responsible Party: Patrick Eiser - DSAL Operations Director
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
2021-001 - Procurement, Suspension and Debarment (Significant Deficiency) Condition: During our testwork over procurement, we noted that there were no procurement policy and payments made to vendors before checking suspension or debarment status on www.sam.gov. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: §200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: DSAL did not establish adequate internal controls and procedures and procurement policy to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: DSAL is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require DSAL to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that DSAL establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: Management agrees with the findings and has provided the accompanying corrective action plan. Estimated Completion Date: November 20, 2022 Responsible Party: Patrick Eiser - DSAL Operations Director
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.