Reporting a determination that an applicant is not qualified for a Federal award.
Finding No. 2023-004 Suspension and Debarment Federal Agency: U.S. Department of Education; U.S. Department of the Treasury Federal Program Name: Special Education Cluster (IDEA); Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 84.027/84.173; 21.027 Federal Award Identification Number and Year: H027A220054 – 2023; SLFRP4547 – 2021 Pass-Through Agency: RI Department of Elementary and Secondary Education, RI Department of Revenue Pass-Through Number(s): 2725-13202-301; 12060-OPM20600-29669 Award Period: 7/1/22-6/30/23; 3/3/21-12/31/24 Type of Finding: Significant Deficiency in Internal Control over Compliance 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 and Coventry Public Schools do 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 and Coventry Public Schools do 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 8 of 8 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 and Coventry Public Schools are at risk for noncompliance with federal grants as it relates to suspension and debarment. Repeat Finding Yes, repeat of prior year finding 2022-008. Recommendation We recommend that the Town and Coventry Public Schools implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods or services. Views of Responsible Officials Management agrees with this finding.
Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) 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, 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 Cost: None. Repeat Finding: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency 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. procedure due to the turnover in the purchasing agent position verification could not be located. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select “Search” from the header menu from any page on SAM.gov 2) In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) 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, 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 Cost: None. Repeat Finding: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency 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. procedure due to the turnover in the purchasing agent position verification could not be located. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select “Search” from the header menu from any page on SAM.gov 2) In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) 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, 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 Cost: None. Repeat Finding: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency 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. procedure due to the turnover in the purchasing agent position verification could not be located. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select “Search” from the header menu from any page on SAM.gov 2) In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) 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, 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 Cost: None. Repeat Finding: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency 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. procedure due to the turnover in the purchasing agent position verification could not be located. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select “Search” from the header menu from any page on SAM.gov 2) In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 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 testing of the major program, 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 Cost: None. 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 is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. 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.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 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 testing of the major program, 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 Cost: None. 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 is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. 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.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 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 testing of the major program, 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 Cost: None. 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 is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. 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.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 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 testing of the major program, 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 Cost: None. 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 is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. 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.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 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 testing of the major program, 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 Cost: None. 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 is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. 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.
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 follow-up to finding 2022-002 we noted that the District reviewed vendors charged to other federal programs but did not verify for the Child Nutrition cluster.
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 follow-up to finding 2022-002 we noted that the District reviewed vendors charged to other federal programs but did not verify for the Child Nutrition cluster.
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 follow-up to finding 2022-002 we noted that the District reviewed vendors charged to other federal programs but did not verify for the Child Nutrition cluster.
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 follow-up to finding 2022-002 we noted that the District reviewed vendors charged to other federal programs but did not verify for the Child Nutrition cluster.
Federal Agency: U.S. Agency for International Development Federal Program Name: Collaboration for African Biodiversity (ABCG III) Assistance Listing Number: 98.001 Federal Award Identification Number and Year: 7200AA20FA0032 - 2023 Pass-Through Agency: World Resources Institute Pass-Through Number(s): FAA-7200AA20FA0032 Award Period: October 1, 2020 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: In accordance with § 200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal unless the nonfederal entity obtains an exception under §180.135. Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence showing that the suspension and debarment verification occurred before the transaction with the vendor was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not suspended or debarred. Questioned costs: None Context: This is a condition based on testing of AWF's compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and procurement procedures outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the federal government. Repeat Finding: No Recommendation: We recommend management to ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Agency for International Development Federal Program Name: Collaboration for African Biodiversity (ABCG III) Assistance Listing Number: 98.001 Federal Award Identification Number and Year: 7200AA20FA0032 - 2023 Pass-Through Agency: World Resources Institute Pass-Through Number(s): FAA-7200AA20FA0032 Award Period: October 1, 2020 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: In accordance with § 200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal unless the nonfederal entity obtains an exception under §180.135. Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence showing that the suspension and debarment verification occurred before the transaction with the vendor was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not suspended or debarred. Questioned costs: None Context: This is a condition based on testing of AWF's compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and procurement procedures outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the federal government. Repeat Finding: No Recommendation: We recommend management to ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Agency for International Development Federal Program Name: Collaboration for African Biodiversity (ABCG III) Assistance Listing Number: 98.001 Federal Award Identification Number and Year: 7200AA20FA0032 - 2023 Pass-Through Agency: World Resources Institute Pass-Through Number(s): FAA-7200AA20FA0032 Award Period: October 1, 2020 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: In accordance with § 200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal unless the nonfederal entity obtains an exception under §180.135. Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence showing that the suspension and debarment verification occurred before the transaction with the vendor was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not suspended or debarred. Questioned costs: None Context: This is a condition based on testing of AWF's compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and procurement procedures outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the federal government. Repeat Finding: No Recommendation: We recommend management to ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Agency for International Development Federal Program Name: Collaboration for African Biodiversity (ABCG III) Assistance Listing Number: 98.001 Federal Award Identification Number and Year: 7200AA20FA0032 - 2023 Pass-Through Agency: World Resources Institute Pass-Through Number(s): FAA-7200AA20FA0032 Award Period: October 1, 2020 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: In accordance with § 200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal unless the nonfederal entity obtains an exception under §180.135. Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence showing that the suspension and debarment verification occurred before the transaction with the vendor was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not suspended or debarred. Questioned costs: None Context: This is a condition based on testing of AWF's compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and procurement procedures outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the federal government. Repeat Finding: No Recommendation: We recommend management to ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Agency for International Development Federal Program Name: Collaboration for African Biodiversity (ABCG III) Assistance Listing Number: 98.001 Federal Award Identification Number and Year: 7200AA20FA0032 - 2023 Pass-Through Agency: World Resources Institute Pass-Through Number(s): FAA-7200AA20FA0032 Award Period: October 1, 2020 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: In accordance with § 200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal unless the nonfederal entity obtains an exception under §180.135. Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence showing that the suspension and debarment verification occurred before the transaction with the vendor was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not suspended or debarred. Questioned costs: None Context: This is a condition based on testing of AWF's compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and procurement procedures outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the federal government. Repeat Finding: No Recommendation: We recommend management to ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: There is no disagreement with the audit finding.
2023-006 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children CFDA No. 10.553, 10.555, and 10.556) 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 on an annual basis. They are however, checking the status of any new vendors. 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.
2023-006 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children CFDA No. 10.553, 10.555, and 10.556) 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 on an annual basis. They are however, checking the status of any new vendors. 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.
2023-006 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children CFDA No. 10.553, 10.555, and 10.556) 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 on an annual basis. They are however, checking the status of any new vendors. 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.
2023-006 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children CFDA No. 10.553, 10.555, and 10.556) 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 on an annual basis. They are however, checking the status of any new vendors. 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 (National School Lunch Program, School Breakfast Program and Food Distribution Federal Assistance Listing No. 10.555 and 10.553) 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 Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money.
Child Nutrition Cluster – Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program and Food Distribution Federal Assistance Listing No. 10.555 and 10.553) 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 Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money.
Child Nutrition Cluster – Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program and Food Distribution Federal Assistance Listing No. 10.555 and 10.553) 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 Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money.
Reference Number: 2023-001 Prior Year Finding: Yes Federal Agency: U.S. Department of the Treasury & U.S. Environmental Protection Agency Federal Program: Coronavirus State and Local Fiscal Recovery Funds (American Rescue Plan Act) & Clean Water State Revolving Funds Assistance Listing Number: 21.027 & 66.458 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 eight vendors was not documented related to the Coronavirus State and Local Fiscal Recovery Funds program. The suspension and debarment status for four out of five vendors was not documented related to the Clean Water State Revolving Funds program. 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 audit documentation to support their review of suspension and debarment status. Views of responsible officials: The County does check Sam.gov for suspension and debarment transactions. Documentation was retained, but was lost due to a network intrusion. We will remain diligent in documenting our reviews.
Reference Number: 2023-001 Prior Year Finding: Yes Federal Agency: U.S. Department of the Treasury & U.S. Environmental Protection Agency Federal Program: Coronavirus State and Local Fiscal Recovery Funds (American Rescue Plan Act) & Clean Water State Revolving Funds Assistance Listing Number: 21.027 & 66.458 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 eight vendors was not documented related to the Coronavirus State and Local Fiscal Recovery Funds program. The suspension and debarment status for four out of five vendors was not documented related to the Clean Water State Revolving Funds program. 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 audit documentation to support their review of suspension and debarment status. Views of responsible officials: The County does check Sam.gov for suspension and debarment transactions. Documentation was retained, but was lost due to a network intrusion. We will remain diligent in documenting our reviews.
Reference Number: 2023-001 Prior Year Finding: Yes Federal Agency: U.S. Department of the Treasury & U.S. Environmental Protection Agency Federal Program: Coronavirus State and Local Fiscal Recovery Funds (American Rescue Plan Act) & Clean Water State Revolving Funds Assistance Listing Number: 21.027 & 66.458 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 eight vendors was not documented related to the Coronavirus State and Local Fiscal Recovery Funds program. The suspension and debarment status for four out of five vendors was not documented related to the Clean Water State Revolving Funds program. 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 audit documentation to support their review of suspension and debarment status. Views of responsible officials: The County does check Sam.gov for suspension and debarment transactions. Documentation was retained, but was lost due to a network intrusion. We will remain diligent in documenting our reviews.
Reference Number: 2023-001 Prior Year Finding: Yes Federal Agency: U.S. Department of the Treasury & U.S. Environmental Protection Agency Federal Program: Coronavirus State and Local Fiscal Recovery Funds (American Rescue Plan Act) & Clean Water State Revolving Funds Assistance Listing Number: 21.027 & 66.458 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 eight vendors was not documented related to the Coronavirus State and Local Fiscal Recovery Funds program. The suspension and debarment status for four out of five vendors was not documented related to the Clean Water State Revolving Funds program. 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 audit documentation to support their review of suspension and debarment status. Views of responsible officials: The County does check Sam.gov for suspension and debarment transactions. Documentation was retained, but was lost due to a network intrusion. We will remain diligent in documenting our reviews.
Criteria – Under Title 2 U.S. Code of Federal Regulations Part 200.319 “All procurement transaction for the acquisition of property or services required under a Federal awards must be conducted in a manner providing full and open competition consistent with eh standards of this section and 200.320” Also, as required by federal regulations in 2 CFR 200.320 and 2 CFR 200.213 “EPLS (excluded parties list system) review of vendors proposing on a federal project is requested at the time of receipt of proposal through the Federal Awarding Agency Contracting Department.” Condition/Context – For the one new vendor contract entered into during the fiscal year, the County did not follow federal procurement standards. A formal procurement method such as sealed bids, proposals or noncompetitive procurement was not performed and there was no evidence that the County verified the vendor was not suspended or debarred per the federal EPLS prior to entering the contract. We verified that the vendor was not suspended or debarred during the fiscal year 2023. Cause – The individuals overseeing contract procurement applied the normal state level requirements and was not aware the additional federal level requirements applicable due to the grant funds coming from a federal source. Effect – Without following the proper federal policies, the County may be entering into transactions with vendors that have been suspended or debarred. Repeated Finding – This is not a repeated finding. Recommendation – We recommend the County assigns a knowledgeable individual with proper training and skill to complete the procurement process and update policies and procedures for federal awards to ensure that the vendors are checked before entering into a contract. Management’s Response – We concur with the finding. Historically, the procurement process is handled at the department level and departments are expected to understand and comply with the requirements related to the funding source(s) used to procure goods and services. The Health and Human Services department followed our County procurement policy and solicited input from the State, the agency that passes WIC monies to the County, on suggestions for procuring dietitian/nutritionist services. While County policy was followed and input from the State was provided, documentation to support the procurement method used did not illustrate compliance with federal procurement standards and the service provider’s suspension and debarment status was not verified prior to entering into a contract. To mitigate this issue in the future, County Counsel reminded departments of the importance of understanding the requirements tied to the source being used to procure goods and services and to notify Counsel when federal monies are being used. Furthermore, County Counsel will include the suspension and debarment clause in the County’s standard contract templates, and the County Purchasing Policy (4-03) will be updated to reflect the importance of complying with requirements tied to a specific funding source. Lastly, County Counsel and Internal Audit will develop and provide training to departments.
Federal Program Information: Funding Agency: U.S. Department of Agriculture Title: USDA School Breakfast Program and National School Lunch Program FAL Number: 10.553 and 10.555 Passthrough: New Mexico Public Education Department Award Year: 2023 Criteria: §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, sub awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. §200.317 Procurements by states. When procuring property and services under a Federal award, a state must follow the same policies and procedures it uses for procurements from its non-Federal funds. The state will comply with §200.322 Procurement of recovered materials and ensure that every purchase order or other contract includes any clauses required by section §200.326 Contract provisions. All other non-Federal entities, including sub recipients of a state, will follow §§200.318 General procurement standards through 200.326 Contract provisions. §200.318 General procurement standards. (a) The 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 this part. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. APPENDIX II TO PART 200—CONTRACT PROVISIONS FOR NON-FEDERAL ENTITY CONTRACTS UNDER FEDERAL AWARDS In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. (H) Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the government-wide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” https://www.sam.gov/portal/public/SAM/ SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: During our testing of single audit disbursements, we identified a vendor which would meet the requirement of verifying that the vendor was not suspended or debarred or otherwise excluded from receiving the contract which was funded through Federal dollars. The vendor received more than $25,000 in payments from the District from Federal grant sources. The vendor is not currently suspended or debarred from receiving Federal contracts; however, the District did not have proper internal controls in place to verify this prior to the purchase. The District did make improvement in this area for all new work during the year. However, these projects were completed in the year under audit before the District became aware of the requirements above and could not retroactively cure the errors. Cause: District personnel did not verify that vendors which meet the $25,000 thresholds are not suspended, debarred, or otherwise excluded from participating in contracts funded through Federal awards due to a misunderstanding of staff personnel regarding this requirement. Effect: The District is not in compliance with Federal regulations related to the grant and could put funding in jeopardy or require the District to reimburse the program for improper grant distributions. Auditor’s Recommendation: We recommend the District establish a policy and implement procedures regarding large purchases related to Federal grants to insure that no vendors who are suspended, debarred, or otherwise excluded from participating in transactions funded through Federal grants are used. As identified above, there are several methods in which the District can verify vendors are not suspended or debarred. The District may have the vendor provide an annual certification that it is not currently suspended, debarred, or otherwise prevented from receiving Federal dollars. In other occasions in which a single purchase is going to be made, the purchasing procedures should include looking up the vendor on the GSA website, printing a copy of the verification, and placing it in the file with the purchase order. The District has options, and it should establish what method is the least intrusive but also effective in complying with the requirements of the Uniform Grant Guidance. Responsible Official’s Plan: Specific corrective action plan for finding: The Grants Finance Department, Federal Grants Department, Operations Department along with the Purchasing Department will review Vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and Debarment. A printed document from SAM.GOV verifying eligibility for Requisitions over $25K will be attached. Infinite Visions is set up to alert originators entering requisitions over $25,000 to contact Purchasing or Grants Department to check the vendor in SAM.GOV to confirm the vendor is vetted to comply with federal regulations. At the initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document from SAM.GOV verifying eligibility of vendor will be attached to the vendor file. Timeline for completion of corrective action plan: The process was implemented immediately upon awareness of the finding and we are hopeful that all issues have been resolved by FY24. Employee position(s) responsible for meeting the timeline: Grants Specialists, CPO, Finance Specialists, Purchasing Specialist, Federal Grants Coordinator, Federal Grants Specialist
Federal Program Information: Funding Agency: U.S. Department of Interior Title: Rangeland Resource Management FAL Number: 15.237 Passthrough: L20AC00454-1-L21AC10556 (2) Award Year: 2023 Criteria: §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, sub awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. §200.317 Procurements by states. When procuring property and services under a Federal award, a state must follow the same policies and procedures it uses for procurements from its non-Federal funds. The state will comply with §200.322 Procurement of recovered materials and ensure that every purchase order or other contract includes any clauses required by section §200.326 Contract provisions. All other non-Federal entities, including sub recipients of a state, will follow §§200.318 General procurement standards through 200.326 Contract provisions. §200.318 General procurement standards. (a) The 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 this part. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. APPENDIX II TO PART 200—CONTRACT PROVISIONS FOR NON-FEDERAL ENTITY CONTRACTS UNDER FEDERAL AWARDS In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. (H) Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the government-wide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” https://www.sam.gov/portal/public/SAM/ SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Questioned Costs: None Condition: During our testing of single audit disbursements, we identified two vendors which would meet the requirement of verifying that the vendor was not suspended or debarred or otherwise excluded from receiving the contract, which was funded through Federal dollars. The vendors received more than $25,000 in payments from the District from Federal grant sources. The vendors are not currently suspended or debarred from receiving Federal contracts; however, the District did not have proper internal controls in place to verify this prior to the payment. Cause: District personnel were unaware of the requirement to ensure vendors receiving more than $25,000 were not on the suspension and debarment listing. Effect: The District is not in compliance with Federal regulations related to the grant and could put funding in jeopardy or require the District to reimburse the program for improper grant distributions. Auditor’s Recommendation: We recommend the District establish a policy and implement procedures regarding large purchases related to Federal grants to insure that no vendors who are suspended, debarred, or otherwise excluded from participating in transactions funded through Federal grants are used. As identified above, there are several methods in which the District can verify vendors are not suspended or debarred. The District may have the vendor provide an annual certification that it is not currently suspended, debarred, or otherwise prevented from receiving Federal dollars. In other occasions in which a single purchase is going to be made, the purchasing procedures should include looking up the vendor on the GSA website, printing a copy of the verification, and placing it in the file with the purchase order. The District has options, and it should establish what method is the least intrusive, but also effective, in complying with the requirements of the Uniform Grant Guidance. Responsible Official’s Plan: Specific corrective action plan for finding: The procurement Officer of SJSWCD has updated the procurement process on 12/7/2023 that all contractors who will be receiving Federal monies must provide an annual certification that they are not suspended, debarred, inactive, or otherwise excluded from participating in transactions funded through Federal grants. The policy change will be approved at the next board meeting. Timeline for completion of corrective action plan: December 7, 2023 Employee position(s) responsible for meeting the timeline: District Manager/Procurement Officer
Finding: 2023-002 Non-Compliance with Suspension and Debarment Information on the Federal Program: Assistance Listing Number 16.582 Criteria: Under 2 CFR §200.213, 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. Condition: The Association did not consistently perform screenings on its potential or current vendors, suppliers, or contractors that were paid with Federal funds. Cause: The Association does not have a formal policy with respect to screening vendors, suppliers, or contractors in order to adhere to compliance over suspension and debarment. Effect: Failure to screen potential and current vendors, suppliers, contractors, subrecipients, etc. increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Association's accounting system. We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend management develop and implement a formal policy on suspension and debarment. This policy should include a threshold, generally $25,000, for when vendors, suppliers, contractors and sub-contractors/grantees should be screened. All screenings should be conducted prior to signing a contract or issuing payment. We recommend that the Association notify all employees of this policy and ensure that it is enforced during the upcoming fiscal year.
Finding: 2023-002 Non-Compliance with Suspension and Debarment Information on the Federal Program: Assistance Listing Number 16.582 Criteria: Under 2 CFR §200.213, 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. Condition: The Association did not consistently perform screenings on its potential or current vendors, suppliers, or contractors that were paid with Federal funds. Cause: The Association does not have a formal policy with respect to screening vendors, suppliers, or contractors in order to adhere to compliance over suspension and debarment. Effect: Failure to screen potential and current vendors, suppliers, contractors, subrecipients, etc. increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Association's accounting system. We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend management develop and implement a formal policy on suspension and debarment. This policy should include a threshold, generally $25,000, for when vendors, suppliers, contractors and sub-contractors/grantees should be screened. All screenings should be conducted prior to signing a contract or issuing payment. We recommend that the Association notify all employees of this policy and ensure that it is enforced during the upcoming fiscal year.
Finding 2023-003: Non-Compliance with Suspension and Debarment Information on the Federal Program: 93.368 Criteria: 2 CFR §200.213 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. Condition: We noted that while the Foundation does conduct screenings on all vendors, suppliers and consultants, the date that the screening is conducted is not documented. As such, we are unable to determine if the screening was conducted prior to payment or signing of the contract. Cause: The Foundation does not require that the date the screening is conducted be documented. Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or contract signing increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation revise their policy regarding suspension and debarment to require that all screenings are accompanied by the documented date in which they were conducted.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1026 -2021 Pass-Through Agency: Virginia Department of Education Pass-Through Number(s): 179001-600540/452770 Award Period: 3/3/21 – 12/31/24 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: Spotsylvania Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: Spotsylvania Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Repeat Finding: No Recommendation: Spotsylvania School should ensure that employees are following the requirements they have outlined in their procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1026 -2021 Pass-Through Agency: Virginia Department of Education Pass-Through Number(s): 179001-600540/452770 Award Period: 3/3/21 – 12/31/24 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: Spotsylvania Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: Spotsylvania Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Repeat Finding: No Recommendation: Spotsylvania School should ensure that employees are following the requirements they have outlined in their procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1026 -2021 Pass-Through Agency: Virginia Department of Education Pass-Through Number(s): 179001-600540/452770 Award Period: 3/3/21 – 12/31/24 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: Spotsylvania Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: Spotsylvania Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Repeat Finding: No Recommendation: Spotsylvania School should ensure that employees are following the requirements they have outlined in their procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1026 -2021 Pass-Through Agency: Virginia Department of Education Pass-Through Number(s): 179001-600540/452770 Award Period: 3/3/21 – 12/31/24 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: Spotsylvania Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: Spotsylvania Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Repeat Finding: No Recommendation: Spotsylvania School should ensure that employees are following the requirements they have outlined in their procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
III ‐ Findings and Questioned Costs – Major Federal Award Program Finding No. 2023‐002 National Science Foundation ‐ Research and Development Cluster Federal Assistance Listing Number #47.070 ‐ Compliance Requirement Code: I‐Procurement and Suspension and Debarment Criteria In accordance with §200.318(a), General Procurement Standards, 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 General Procurement Standards. Additionally, §200.318(i) states that the non‐federal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, non‐federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition For the procurement samples tested, Management did not provide adequate supporting documentation for the procurement including ensuring proper suspension and debarment checks were performed. Cause The Organization did not have adequate policies, procedures, and controls in place to ensure compliance with the general procurement standards and suspension and debarment requirements. Effect or Potential Effect Failure to perform procurement procedures in accordance with a written policy that complies with the Uniform Guidance could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Not applicable. Context For three procurement samples out of a total of three tested, management did not provide adequate supporting documentation for the procurement transaction. Repeat Finding: No Recommendation We recommend that the Organization establish written procurement policies and procedures to ensure that Organization is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Views of Responsible Officials Our understanding of the finding is that it pertains to the following sections of 2 CFR 180: § 180.220 Are any procurement contracts included as covered transactions? (a) Covered transactions under this part— (1) Do not include any procurement contracts awarded directly by a Federal agency; but (2) Do include some procurement contracts awarded by non Federal participants in nonprocurement covered transactions. (b) Specifically, a contract for goods or services is a covered transaction if any of the following applies: (1) The contract is awarded by a participant in a nonprocurement transaction that is covered under §180.210, and the amount of the contract is expected to equal or exceed $25,000. (2) The contract requires the consent of an official of a Federal agency. In that case, the contract, regardless of the amount, always is a covered transaction, and it does not matter who awarded it. For example, it could be a subcontract awarded by a contractor at a tier below a nonprocurement transaction, as shown in the appendix to this part. § 180.300 What must I do before I enter into a covered transaction with another person at the next lower tier? When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this 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. To support compliance with these requirements, MGHPCC controls for federal programs in place in FY23 included the following provision: Criteria for approval of Purchase Orders above $25,000 include a check to ensure that the vendors are not suspended disbarred, or otherwise excluded from participating in a covered transaction as defined in 2CFR 180.220 and 2CFR 180.300. To address the finding noted above, we have added the following documentation requirement: Policy has been updated to require that the check be documented by capturing a copy of the entity information database entry at www.sam.gov as part of the Purchase Order approval process for vendorswho exceed the threshold defined in 2CFR 180.220 and 2CFR 180.300. The entity information database report includes a time stamp, which serves as an indication of when the database entry was checked.
2023-006 - Internal Control Over Compliance and Compliance – Procurement, Suspension and Debarment Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Criteria - In accordance with 2 CFR §200.318(a), General Procurement Standards, the 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 General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition – During our testing of the procurement, suspension and debarment compliance requirements, we identified one procurement sample out of a total of two procurement samples tested wherein management was unable to provide evidence that the suspension and debarment check was performed prior to entering into contract with the vendor. Management has subsequently determined that the vendor was not suspended or debarred. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center’s personnel did not adhere to NGA Center’s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a covered transaction. Effect – Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering a contract with an entity that is barred from performing work for the Federal government. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
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 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 two of three 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 2022-001) 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 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 two of three 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 2022-001) 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 Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1026 -2021 Pass-Through Agency: Virginia Department of Education Pass-Through Number(s): 179001-600540/452770 Award Period: 3/3/21 – 12/31/24 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: Spotsylvania Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: Spotsylvania Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Repeat Finding: No Recommendation: Spotsylvania School should ensure that employees are following the requirements they have outlined in their procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1026 -2021 Pass-Through Agency: Virginia Department of Education Pass-Through Number(s): 179001-600540/452770 Award Period: 3/3/21 – 12/31/24 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: Spotsylvania Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: Spotsylvania Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Repeat Finding: No Recommendation: Spotsylvania School should ensure that employees are following the requirements they have outlined in their procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1026 -2021 Pass-Through Agency: Virginia Department of Education Pass-Through Number(s): 179001-600540/452770 Award Period: 3/3/21 – 12/31/24 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: Spotsylvania Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: Spotsylvania Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Repeat Finding: No Recommendation: Spotsylvania School should ensure that employees are following the requirements they have outlined in their procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1026 -2021 Pass-Through Agency: Virginia Department of Education Pass-Through Number(s): 179001-600540/452770 Award Period: 3/3/21 – 12/31/24 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: Spotsylvania Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: Spotsylvania Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Repeat Finding: No Recommendation: Spotsylvania School should ensure that employees are following the requirements they have outlined in their procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
Finding No. 2023-004 Suspension and Debarment Federal Agency: U.S. Department of Education; U.S. Department of the Treasury Federal Program Name: Special Education Cluster (IDEA); Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 84.027/84.173; 21.027 Federal Award Identification Number and Year: H027A220054 – 2023; SLFRP4547 – 2021 Pass-Through Agency: RI Department of Elementary and Secondary Education, RI Department of Revenue Pass-Through Number(s): 2725-13202-301; 12060-OPM20600-29669 Award Period: 7/1/22-6/30/23; 3/3/21-12/31/24 Type of Finding: Significant Deficiency in Internal Control over Compliance 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 and Coventry Public Schools do 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 and Coventry Public Schools do 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 8 of 8 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 and Coventry Public Schools are at risk for noncompliance with federal grants as it relates to suspension and debarment. Repeat Finding Yes, repeat of prior year finding 2022-008. Recommendation We recommend that the Town and Coventry Public Schools implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods or services. Views of Responsible Officials Management agrees with this finding.
Finding No. 2023-004 Suspension and Debarment Federal Agency: U.S. Department of Education; U.S. Department of the Treasury Federal Program Name: Special Education Cluster (IDEA); Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 84.027/84.173; 21.027 Federal Award Identification Number and Year: H027A220054 – 2023; SLFRP4547 – 2021 Pass-Through Agency: RI Department of Elementary and Secondary Education, RI Department of Revenue Pass-Through Number(s): 2725-13202-301; 12060-OPM20600-29669 Award Period: 7/1/22-6/30/23; 3/3/21-12/31/24 Type of Finding: Significant Deficiency in Internal Control over Compliance 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 and Coventry Public Schools do 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 and Coventry Public Schools do 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 8 of 8 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 and Coventry Public Schools are at risk for noncompliance with federal grants as it relates to suspension and debarment. Repeat Finding Yes, repeat of prior year finding 2022-008. Recommendation We recommend that the Town and Coventry Public Schools implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods or services. Views of Responsible Officials Management agrees with this finding.