Reference Number: 2022-001 Suspension and Debarment Prior Year Finding: No Federal Agency: U.S. Treasury Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Award Number and Year: None, 2002 Compliance Requirement: Suspension and Debarment Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: ? 200.214 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. The regulations in 2 CFR part 180 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. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: ACPS did not maintain consistently documentation of vendor?s suspension and debarment status. ACPS has procedures for verifying a vendor?s suspension and debarment during the procurement process; however, the documentation of the results were not maintained in the vendor?s file. Context: The suspension and debarment verification was not available for review for two of the seven contracts selected for testing. Questioned costs: CLA was unable to determine the vendor?s suspended or debarred status prior to the contract date. The contracts were multi-year, issued before 2022. Cause: ACPS did not maintain the verification of the vendor?s suspension and debarment status in the procurement records. Effect: ACPS is unable to support the vendor?s suspension and debarment status prior to the contract date. Recommendation: We recommend that ACPS consistently follow their procurement procedures and enhance procedures to ensure that all required procurement documentation is maintained in the vendor?s procurement file. Views of responsible officials: ACPS agrees with the finding
Reference Number: 2022-001 Suspension and Debarment Prior Year Finding: No Federal Agency: U.S. Treasury Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Award Number and Year: None, 2002 Compliance Requirement: Suspension and Debarment Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: ? 200.214 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. The regulations in 2 CFR part 180 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. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: ACPS did not maintain consistently documentation of vendor?s suspension and debarment status. ACPS has procedures for verifying a vendor?s suspension and debarment during the procurement process; however, the documentation of the results were not maintained in the vendor?s file. Context: The suspension and debarment verification was not available for review for two of the seven contracts selected for testing. Questioned costs: CLA was unable to determine the vendor?s suspended or debarred status prior to the contract date. The contracts were multi-year, issued before 2022. Cause: ACPS did not maintain the verification of the vendor?s suspension and debarment status in the procurement records. Effect: ACPS is unable to support the vendor?s suspension and debarment status prior to the contract date. Recommendation: We recommend that ACPS consistently follow their procurement procedures and enhance procedures to ensure that all required procurement documentation is maintained in the vendor?s procurement file. Views of responsible officials: ACPS agrees with the finding
Reference Number: 2022-001 Suspension and Debarment Prior Year Finding: No Federal Agency: U.S. Treasury Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Award Number and Year: None, 2002 Compliance Requirement: Suspension and Debarment Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: ? 200.214 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. The regulations in 2 CFR part 180 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. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: ACPS did not maintain consistently documentation of vendor?s suspension and debarment status. ACPS has procedures for verifying a vendor?s suspension and debarment during the procurement process; however, the documentation of the results were not maintained in the vendor?s file. Context: The suspension and debarment verification was not available for review for two of the seven contracts selected for testing. Questioned costs: CLA was unable to determine the vendor?s suspended or debarred status prior to the contract date. The contracts were multi-year, issued before 2022. Cause: ACPS did not maintain the verification of the vendor?s suspension and debarment status in the procurement records. Effect: ACPS is unable to support the vendor?s suspension and debarment status prior to the contract date. Recommendation: We recommend that ACPS consistently follow their procurement procedures and enhance procedures to ensure that all required procurement documentation is maintained in the vendor?s procurement file. Views of responsible officials: ACPS agrees with the finding
Reference Number: 2022-001 Suspension and Debarment Prior Year Finding: No Federal Agency: U.S. Treasury Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Award Number and Year: None, 2002 Compliance Requirement: Suspension and Debarment Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: ? 200.214 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. The regulations in 2 CFR part 180 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. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: ACPS did not maintain consistently documentation of vendor?s suspension and debarment status. ACPS has procedures for verifying a vendor?s suspension and debarment during the procurement process; however, the documentation of the results were not maintained in the vendor?s file. Context: The suspension and debarment verification was not available for review for two of the seven contracts selected for testing. Questioned costs: CLA was unable to determine the vendor?s suspended or debarred status prior to the contract date. The contracts were multi-year, issued before 2022. Cause: ACPS did not maintain the verification of the vendor?s suspension and debarment status in the procurement records. Effect: ACPS is unable to support the vendor?s suspension and debarment status prior to the contract date. Recommendation: We recommend that ACPS consistently follow their procurement procedures and enhance procedures to ensure that all required procurement documentation is maintained in the vendor?s procurement file. Views of responsible officials: ACPS agrees with the finding
Reference Number: 2022-001 Suspension and Debarment Prior Year Finding: No Federal Agency: U.S. Treasury Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Award Number and Year: None, 2002 Compliance Requirement: Suspension and Debarment Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: ? 200.214 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. The regulations in 2 CFR part 180 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. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: ACPS did not maintain consistently documentation of vendor?s suspension and debarment status. ACPS has procedures for verifying a vendor?s suspension and debarment during the procurement process; however, the documentation of the results were not maintained in the vendor?s file. Context: The suspension and debarment verification was not available for review for two of the seven contracts selected for testing. Questioned costs: CLA was unable to determine the vendor?s suspended or debarred status prior to the contract date. The contracts were multi-year, issued before 2022. Cause: ACPS did not maintain the verification of the vendor?s suspension and debarment status in the procurement records. Effect: ACPS is unable to support the vendor?s suspension and debarment status prior to the contract date. Recommendation: We recommend that ACPS consistently follow their procurement procedures and enhance procedures to ensure that all required procurement documentation is maintained in the vendor?s procurement file. Views of responsible officials: ACPS agrees with the finding
Reference Number: 2022-001 Suspension and Debarment Prior Year Finding: No Federal Agency: U.S. Treasury Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Award Number and Year: None, 2002 Compliance Requirement: Suspension and Debarment Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: ? 200.214 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. The regulations in 2 CFR part 180 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. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: ACPS did not maintain consistently documentation of vendor?s suspension and debarment status. ACPS has procedures for verifying a vendor?s suspension and debarment during the procurement process; however, the documentation of the results were not maintained in the vendor?s file. Context: The suspension and debarment verification was not available for review for two of the seven contracts selected for testing. Questioned costs: CLA was unable to determine the vendor?s suspended or debarred status prior to the contract date. The contracts were multi-year, issued before 2022. Cause: ACPS did not maintain the verification of the vendor?s suspension and debarment status in the procurement records. Effect: ACPS is unable to support the vendor?s suspension and debarment status prior to the contract date. Recommendation: We recommend that ACPS consistently follow their procurement procedures and enhance procedures to ensure that all required procurement documentation is maintained in the vendor?s procurement file. Views of responsible officials: ACPS agrees with the finding
Reference Number: 2022-001 Suspension and Debarment Prior Year Finding: No Federal Agency: U.S. Treasury Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Award Number and Year: None, 2002 Compliance Requirement: Suspension and Debarment Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: ? 200.214 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. The regulations in 2 CFR part 180 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. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: ACPS did not maintain consistently documentation of vendor?s suspension and debarment status. ACPS has procedures for verifying a vendor?s suspension and debarment during the procurement process; however, the documentation of the results were not maintained in the vendor?s file. Context: The suspension and debarment verification was not available for review for two of the seven contracts selected for testing. Questioned costs: CLA was unable to determine the vendor?s suspended or debarred status prior to the contract date. The contracts were multi-year, issued before 2022. Cause: ACPS did not maintain the verification of the vendor?s suspension and debarment status in the procurement records. Effect: ACPS is unable to support the vendor?s suspension and debarment status prior to the contract date. Recommendation: We recommend that ACPS consistently follow their procurement procedures and enhance procedures to ensure that all required procurement documentation is maintained in the vendor?s procurement file. Views of responsible officials: ACPS agrees with the finding
Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Pass-Through Agency: Massachusetts Department of Elementary & Secondary Education Pass-Through Number(s): 09-056 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 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all vendors in our statistically valid sample (3 of 3), the Town did not document its verification that vendors are not suspended or debarred from participation in Federal assistance programs or activities. The vendors were not suspended or debarred. Questioned Costs: None. Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend to annually (at a minimum) 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. See Corrective Action Plan.
Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Pass-Through Agency: Massachusetts Department of Elementary & Secondary Education Pass-Through Number(s): 09-056 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 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all vendors in our statistically valid sample (3 of 3), the Town did not document its verification that vendors are not suspended or debarred from participation in Federal assistance programs or activities. The vendors were not suspended or debarred. Questioned Costs: None. Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend to annually (at a minimum) 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. See Corrective Action Plan.
Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Pass-Through Agency: Massachusetts Department of Elementary & Secondary Education Pass-Through Number(s): 09-056 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 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all vendors in our statistically valid sample (3 of 3), the Town did not document its verification that vendors are not suspended or debarred from participation in Federal assistance programs or activities. The vendors were not suspended or debarred. Questioned Costs: None. Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend to annually (at a minimum) 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. See Corrective Action Plan.
Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Education Stabilization Fund ? Higher Education Emergency Relief Fund - Institutional Portion (Assistance Listing No. 84.425F)Grant Award Period: July 1, 2021 through June 30, 2022 Grant Identification Numbers: P425F203954 ? 20A Compliance Requirement: Procurement, Suspension and Debarment Criteria: 2 CFR 200.318(a) requires the non-Federal entity to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implemented at 2 CFR 180.300. 2 CFR 180.300 specifies that before entering into a covered transaction with another person at the next lower tier, the entity must verify that the counterparty with whom they intend to do business is not excluded or disqualified. 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include procedures to ensure compliance with procurement, suspension and debarment standards. Conditions Found: During the audit, it was identified that the College did not have a procurement policy in order to comply with 2 CFR 200.318(a). As a result of the lack of a policy, expenditures were made that were not in compliance with the procurement requirements of 2 CFR 200.317 through 2 CFR 200.327. Additionally, it was identified that the College did not obtain evidence that the expenditures made during the period were in compliance with the suspension and debarment requirements of 2 CFR 200.214 and 2 CFR 180.300. Further, it was identified that the College did not have effective internal controls over procurement, suspension and debarment in accordance with 2 CFR 200.303. Total expenditures for 84.425F that were subject to procurement, suspension and debarment compliance requirements were $847,652. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Not determinable Repeat Finding: This finding is a repeat finding in the immediately prior audit. In the prior year, this was reported as finding 2021-001. Cause and Effect: The College did not perform procedures to evidence that the transactions entered into were with counterparties which met the requirements of 2 CFR 200.214 and 2 CFR 180.300. The College did not have an effective system of internal control in place to ensure the procurement, suspension and debarment compliance requirements in 2 CFR 200.317 through 200.327 and 2 CFR 200.214 and 2 CFR 180.300. The College does not typically expend federal awards that are subject to the Uniform Guidance procurement requirements, and as such, management did not have policies in place prior to receiving these federal awards to comply with procurement, suspension and debarment compliance requirements. In response to the prior year finding, management is in process of implementing procurement policies to meet the requirements of 2 CFR sections 200.317 through 200.327. Recommendation: We recommend the College enhance its internal control to ensure that the College has a policy and effective internal controls in place to ensure that the College conforms to required federal procurement, suspension and debarment procedures. View of Responsible Officials: We concur with the finding and are in the process of finalizing policies and procedures to comply with procurement, suspension and debarment standards. Beginning in April 2022, in response to the prior year finding, the College began to ensure vendors were not suspended and debarred for all HEERF funds, including reviewing prior vendors with which HEERF funds were expended. Further, management began obtaining quotes for certain purchases that are being reimbursed by HEERF funds. Consistent with our corrective action plan, we implemented formal written policies and procedures during fiscal year 2023.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, 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. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, 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. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, 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. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, 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. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
CONDITION: In connection with the Cambria Heights School District’s RTU Replacement Project, the District did not perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Cambria Heights School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: Hranec Sheet Metal, Inc. - $157,725, Westmoreland Electric Services – $20,837. RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – CFDA 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance is not verified for all covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2021-003. Recommendation: The School should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – CFDA 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance is not verified for all covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2021-003. Recommendation: The School should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – CFDA 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance is not verified for all covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2021-003. Recommendation: The School should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – CFDA 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance is not verified for all covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2021-003. Recommendation: The School should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $342,999 Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $342,999 Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $342,999 Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.
U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $342,999 Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts? Department of Elementary and Secondary Education Child Nutrition Cluster ? CFDA 10.553 & 10.555 COVID-19 ? Child Nutrition Cluster ? CFDA 10.555 Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Cause: The School experienced turnover during the year and could not located the appropriate files. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts? Department of Elementary and Secondary Education Child Nutrition Cluster ? CFDA 10.553 & 10.555 COVID-19 ? Child Nutrition Cluster ? CFDA 10.555 Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Cause: The School experienced turnover during the year and could not located the appropriate files. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts? Department of Elementary and Secondary Education Child Nutrition Cluster ? CFDA 10.553 & 10.555 COVID-19 ? Child Nutrition Cluster ? CFDA 10.555 Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Cause: The School experienced turnover during the year and could not located the appropriate files. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts? Department of Elementary and Secondary Education Child Nutrition Cluster ? CFDA 10.553 & 10.555 COVID-19 ? Child Nutrition Cluster ? CFDA 10.555 Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Cause: The School experienced turnover during the year and could not located the appropriate files. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) 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.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) 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.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) 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.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) 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.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) 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.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) 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.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) 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.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) 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.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) 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.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) 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.
2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-373304-DPI-SB-546, 2022-373304-DPI-NSL-547 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires District approval of the contracts after consortium finishes the proposal process and selects the prime vendors for the year. Questioned costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files, and obtain District Administrator and Board approval of contracts as required by District policy. This was not done for both procurement transactions in our sample. District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-373304-DPI-SB-546, 2022-373304-DPI-NSL-547 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires District approval of the contracts after consortium finishes the proposal process and selects the prime vendors for the year. Questioned costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files, and obtain District Administrator and Board approval of contracts as required by District policy. This was not done for both procurement transactions in our sample. District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-373304-DPI-SB-546, 2022-373304-DPI-NSL-547 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires District approval of the contracts after consortium finishes the proposal process and selects the prime vendors for the year. Questioned costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files, and obtain District Administrator and Board approval of contracts as required by District policy. This was not done for both procurement transactions in our sample. District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status. Views of responsible officials: There is no disagreement with the audit finding.
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
United States Department of Agriculture Federal Assistance Listing Number 10.558 Child and Adult Care Food Program Criteria or specific requirement: Procurement and Suspension and Debarment (2 CFR 200.214, 2 CFR 200.318) Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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 have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. Condition: Procurement records were not maintained and the Organization's procurement policy was not in compliance with Uniform Guidance. Questioned Costs: None Context: A sample of one vendor was tested out of the total population of 10 vendors. Procurement procedures were not completed for the one vendor. The sampling methodology used is not and is not intended to be statistically valid. Effect: Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause: The Organization did not have proper oversight to ensure procurement procedures were completed. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend implementing procurement policies that comply with the Uniform Guidance and procedures to ensure procurement requirements as required by grantors are being met. Views of Responsible Officials and Planned Corrective Actions: Management concurs with findings and plans to implement the recommendations above. Starting in August 2023, SADCCF will notify potential bidders of the opportunity to bid on the USDA meal program by radio announcement.
Statement of Condition: During our testing of internal control policies and procedures over procurement and suspension and debarment, we noted that management had established a formal purchasing policy, however, the policy did not address suspension and debarment and no procedures were established to ensure that purchases or subawards made under covered transactions were not made to parties that were suspended or debarred. Criteria: In accordance with the OMB compliance requirements and the Code of Federal Regulations (2 CFR 200.214), management must create and monitor internal control policies and procedures to ensure that when the organization enters into a covered transaction with a vendor or subrecipient, policies and procedures are performed to ensure that the vendor or subrecipient is not suspended or debarred or otherwise excluded from participating in the transaction. Cause: Management did not have the proper internal control policies and procedures to monitor vendors or subrecipients nor did they have a proper understanding of suspension and debarment requirements under the OMB compliance requirements and the Code of Federal Regulations (2 CFR 200.214). Effect: As a result, the client was not in compliance with the suspension and debarment attribute as required. Fortunately, no vendors utilized during the year ended June 30, 2022 were listed as suspended or debarred. Recommendation: We recommend that management develop procedures to ensure suspension and debarment procedures are performed for all new vendors and subrecipients. In addition, recurring vendors and subrecipients should be monitored annually to ensure there is no suspension or debarment of that vendor or subrecipient. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at www.sam.gov, (2) collecting a certification from the entity, or (2) adding a clause or condition to the covered transaction with that vendor or subrecipient.
Statement of Condition: During our testing of internal control policies and procedures over procurement and suspension and debarment, we noted that management had established a formal purchasing policy, however, the policy did not address suspension and debarment and no procedures were established to ensure that purchases or subawards made under covered transactions were not made to parties that were suspended or debarred. Criteria: In accordance with the OMB compliance requirements and the Code of Federal Regulations (2 CFR 200.214), management must create and monitor internal control policies and procedures to ensure that when the organization enters into a covered transaction with a vendor or subrecipient, policies and procedures are performed to ensure that the vendor or subrecipient is not suspended or debarred or otherwise excluded from participating in the transaction. Cause: Management did not have the proper internal control policies and procedures to monitor vendors or subrecipients nor did they have a proper understanding of suspension and debarment requirements under the OMB compliance requirements and the Code of Federal Regulations (2 CFR 200.214). Effect: As a result, the client was not in compliance with the suspension and debarment attribute as required. Fortunately, no vendors utilized during the year ended June 30, 2022 were listed as suspended or debarred. Recommendation: We recommend that management develop procedures to ensure suspension and debarment procedures are performed for all new vendors and subrecipients. In addition, recurring vendors and subrecipients should be monitored annually to ensure there is no suspension or debarment of that vendor or subrecipient. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at www.sam.gov, (2) collecting a certification from the entity, or (2) adding a clause or condition to the covered transaction with that vendor or subrecipient.