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.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 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 purchases and contracts to be authorized prior to Board approval of monthly expenditures. 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 document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The 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 however the vendor was determined to not be on the suspended and debarred list. 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. The 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 Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 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 purchases and contracts to be authorized prior to Board approval of monthly expenditures. 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 document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The 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 however the vendor was determined to not be on the suspended and debarred list. 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. The 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 Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 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 purchases and contracts to be authorized prior to Board approval of monthly expenditures. 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 document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The 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 however the vendor was determined to not be on the suspended and debarred list. 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. The 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 Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 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 purchases and contracts to be authorized prior to Board approval of monthly expenditures. 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 document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The 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 however the vendor was determined to not be on the suspended and debarred list. 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. The 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 Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 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 purchases and contracts to be authorized prior to Board approval of monthly expenditures. 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 document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The 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 however the vendor was determined to not be on the suspended and debarred list. 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. The 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 Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 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 purchases and contracts to be authorized prior to Board approval of monthly expenditures. 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 document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The 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 however the vendor was determined to not be on the suspended and debarred list. 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. The 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 Reasonable Officials: District does not have any disagreement with the audit finding.
(2022-066) Title: Internal control over ELC program suspension and debarment needs improvement Prior Year Findings: None State Department: Health and Human Services State Bureau: Division of Contract Management Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (COVID-19) Assistance Listing Number: 93.323 Federal Award Identification Number: NU50CK000523 Compliance Area: Procurement and suspension and debarment Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 180.220 and .300; Division of Contract Management Policy The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR 180.220. The Division of Contract Management (DCM) requires all subrecipients to register in the System of Award Management (SAM) prior to awarding Federal funds to a recipient. DCM?s policy also requires annual verification, review and documentation of suspension and debarment compliance obtained from the SAM website. This document is required to be retained for each subrecipient that administers the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) grant. Condition: The Department of Health and Human Services? DCM administers subrecipient contracts for the ELC program. Included in all contracts is a Debarment, Performance, and Non- Collusion Certification. Annually, contract administrators are responsible for verifying that entities are not suspended or debarred on the SAM website. The Office of the State Auditor (OSA) selected eight subrecipients for testing compliance with suspension and debarment regulations. DCM could not provide documented support that: ? review and verification procedures were completed for five of the eight subrecipients tested. ? one subrecipient was registered on the SAM website. As a result, compliance with suspension and debarment could not be verified. The Department paid $54,423 to the subrecipient. OSA selected a non-statistical random sample. Context: The Department provided $5.9 million to the 43 subrecipients that administered the ELC program during fiscal year 2022. Cause: ? Lack of adequate procedures ? Lack of supervisory oversight Effect: ? Potential questioned costs and disallowances ? Noncompliance with Federal regulations Recommendation: We recommend that the Department implement additional procedures to ensure that verification of suspension and debarment procedures are performed, properly documented, and retained. This will ensure that the Department does not enter into an agreement with a suspended or debarred entity. Corrective Action Plan: See F-24 Management?s Response: The Department disagrees with this finding. The Uniform Guidance part 200.214 identifies that non-Federal entities are subject to the non-procurement debarment and suspension regulations in 2 CFR part 180. 2 CFR part 180 requires that ?when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.? The Department meets this requirement as part of the contracting process by collecting certifications from the Community Agencies stating that they are not suspended or debarred. Therefore, we are in compliance with the Federal requirements for Suspension and debarment. The intent of the Department?s policy to utilize the System for Award Management Exclusions (SAM) is to be an optional and additional assurance to the required collection of certifications that the next lower tier persons are not suspended or debarred. The SAM is utilized as time and resources permit and is not intended to replace the certifications. Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: DCM established the following policies to ensure compliance with Federal regulations: ? Subrecipients must register with the SAM prior to receiving Federal funds. ? Annual verification that the subrecipient is not suspended or debarred must be completed by obtaining and retaining such information from the SAM website. ? A Debarment, Performance, and Non-Collusion Certification is included in the subrecipient contract. One subrecipient was not registered with the SAM and the Department could not provide documentation to support that verification was performed for five subrecipients. It is the responsibility of the Department to implement policies and procedures to ensure compliance with Federal regulations. The Department has established such policies and identified these policies as the control mechanism to ascertain that the Department does not contract subrecipients who are suspended or debarred. To attest that a policy is optional negates the effectiveness of the control mechanism. The Department did not follow its established policies; therefore, a failure in the control process exists. The finding remains as stated. (State Number: 22-1156-03)
(2022-066) Title: Internal control over ELC program suspension and debarment needs improvement Prior Year Findings: None State Department: Health and Human Services State Bureau: Division of Contract Management Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (COVID-19) Assistance Listing Number: 93.323 Federal Award Identification Number: NU50CK000523 Compliance Area: Procurement and suspension and debarment Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 180.220 and .300; Division of Contract Management Policy The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR 180.220. The Division of Contract Management (DCM) requires all subrecipients to register in the System of Award Management (SAM) prior to awarding Federal funds to a recipient. DCM?s policy also requires annual verification, review and documentation of suspension and debarment compliance obtained from the SAM website. This document is required to be retained for each subrecipient that administers the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) grant. Condition: The Department of Health and Human Services? DCM administers subrecipient contracts for the ELC program. Included in all contracts is a Debarment, Performance, and Non- Collusion Certification. Annually, contract administrators are responsible for verifying that entities are not suspended or debarred on the SAM website. The Office of the State Auditor (OSA) selected eight subrecipients for testing compliance with suspension and debarment regulations. DCM could not provide documented support that: ? review and verification procedures were completed for five of the eight subrecipients tested. ? one subrecipient was registered on the SAM website. As a result, compliance with suspension and debarment could not be verified. The Department paid $54,423 to the subrecipient. OSA selected a non-statistical random sample. Context: The Department provided $5.9 million to the 43 subrecipients that administered the ELC program during fiscal year 2022. Cause: ? Lack of adequate procedures ? Lack of supervisory oversight Effect: ? Potential questioned costs and disallowances ? Noncompliance with Federal regulations Recommendation: We recommend that the Department implement additional procedures to ensure that verification of suspension and debarment procedures are performed, properly documented, and retained. This will ensure that the Department does not enter into an agreement with a suspended or debarred entity. Corrective Action Plan: See F-24 Management?s Response: The Department disagrees with this finding. The Uniform Guidance part 200.214 identifies that non-Federal entities are subject to the non-procurement debarment and suspension regulations in 2 CFR part 180. 2 CFR part 180 requires that ?when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.? The Department meets this requirement as part of the contracting process by collecting certifications from the Community Agencies stating that they are not suspended or debarred. Therefore, we are in compliance with the Federal requirements for Suspension and debarment. The intent of the Department?s policy to utilize the System for Award Management Exclusions (SAM) is to be an optional and additional assurance to the required collection of certifications that the next lower tier persons are not suspended or debarred. The SAM is utilized as time and resources permit and is not intended to replace the certifications. Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: DCM established the following policies to ensure compliance with Federal regulations: ? Subrecipients must register with the SAM prior to receiving Federal funds. ? Annual verification that the subrecipient is not suspended or debarred must be completed by obtaining and retaining such information from the SAM website. ? A Debarment, Performance, and Non-Collusion Certification is included in the subrecipient contract. One subrecipient was not registered with the SAM and the Department could not provide documentation to support that verification was performed for five subrecipients. It is the responsibility of the Department to implement policies and procedures to ensure compliance with Federal regulations. The Department has established such policies and identified these policies as the control mechanism to ascertain that the Department does not contract subrecipients who are suspended or debarred. To attest that a policy is optional negates the effectiveness of the control mechanism. The Department did not follow its established policies; therefore, a failure in the control process exists. The finding remains as stated. (State Number: 22-1156-03)
FINDING 2022-002 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-011-PN01, 21619-011-PN01, 22611-011-PN01 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation was a member of the East Central Indiana Special Services Cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The Cooperative entered into one applicable contract during the audit period, but did not perform procedures to ensure compliance with requirements regarding verification that the vendor was not suspended or debarred from participation in federal programs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 16 FRANKLIN COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." 2 CFR 200.214 states: "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." Cause Management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 17 FRANKLIN COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-011-PN01, 21619-011-PN01, 22611-011-PN01 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation was a member of the East Central Indiana Special Services Cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The Cooperative entered into one applicable contract during the audit period, but did not perform procedures to ensure compliance with requirements regarding verification that the vendor was not suspended or debarred from participation in federal programs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 16 FRANKLIN COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." 2 CFR 200.214 states: "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." Cause Management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 17 FRANKLIN COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
See Schedule of Findings and Questioned Costs for chart/table 2022-001: Procurement and Suspension and Debarment Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Per 2 CFR 200.214, non-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. The regulations in 2 CFR Part 180 restrict awards, sub-awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from, or ineligible for, participation in Federal Assistance programs or activities. Per 2 CFR 180.220, non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Covered transactions include contracts for goods and services awarded under a nonprocurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., sub-awards to subrecipients), irrespective of award amount, are considered covered transactions unless they are exempt as provided in 2 CFR Section 180.215. Condition/context: Five transactions were subject to the requirements of procurement based on the transaction price. Of the three transactions tested during the audit, all three were identified as not having the proper documentation supporting the procurement method. Five vendors were subject to the requirements of suspension and debarment. Of the three vendors tested during the audit, all three were identified as not having the proper documentation supporting the review of the suspension and debarment requirements prior to funds being expended. None of the entities were suspended or debarred. Questioned costs: $0 Cause: While the College has a procurement policy in place that appropriately addresses procurement, suspension and debarment, the policy was not properly followed, resulting in a lack of supporting documentation for the procurement and review of the suspension and debarment of vendors in the fiscal year. When the pandemic originally began, exceptions from competitive procurement requirements of the Uniform Guidance could be accepted if a public emergency would not permit a delay; however, the flexibility from competitive procurement has been reduced as it is unlikely the same circumstances would be occurring. The College was still operating under this previous flexibility and utilized prior vendors through sole source contracts. Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ? 200.208. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: No. Recommendation: We recommend that management ensure it is staying updated with changes in guidance and program requirements. In addition, for more consistent application, we recommend that the procurement policy be modified to more clearly state that documentation will be maintained to identify and maintain proper supporting documentation for the method of procurement utilized and for the review of the suspension and debarment requirement. Furthermore, we recommend that the procurement policy be modified to more clearly state vendors with a transaction, in the aggregate, greater than the micro-purchase threshold are required to be procured under approved procurement methods. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
See Schedule of Findings and Questioned Costs for chart/table 2022-001: Procurement and Suspension and Debarment Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Per 2 CFR 200.214, non-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. The regulations in 2 CFR Part 180 restrict awards, sub-awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from, or ineligible for, participation in Federal Assistance programs or activities. Per 2 CFR 180.220, non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Covered transactions include contracts for goods and services awarded under a nonprocurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., sub-awards to subrecipients), irrespective of award amount, are considered covered transactions unless they are exempt as provided in 2 CFR Section 180.215. Condition/context: Five transactions were subject to the requirements of procurement based on the transaction price. Of the three transactions tested during the audit, all three were identified as not having the proper documentation supporting the procurement method. Five vendors were subject to the requirements of suspension and debarment. Of the three vendors tested during the audit, all three were identified as not having the proper documentation supporting the review of the suspension and debarment requirements prior to funds being expended. None of the entities were suspended or debarred. Questioned costs: $0 Cause: While the College has a procurement policy in place that appropriately addresses procurement, suspension and debarment, the policy was not properly followed, resulting in a lack of supporting documentation for the procurement and review of the suspension and debarment of vendors in the fiscal year. When the pandemic originally began, exceptions from competitive procurement requirements of the Uniform Guidance could be accepted if a public emergency would not permit a delay; however, the flexibility from competitive procurement has been reduced as it is unlikely the same circumstances would be occurring. The College was still operating under this previous flexibility and utilized prior vendors through sole source contracts. Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ? 200.208. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: No. Recommendation: We recommend that management ensure it is staying updated with changes in guidance and program requirements. In addition, for more consistent application, we recommend that the procurement policy be modified to more clearly state that documentation will be maintained to identify and maintain proper supporting documentation for the method of procurement utilized and for the review of the suspension and debarment requirement. Furthermore, we recommend that the procurement policy be modified to more clearly state vendors with a transaction, in the aggregate, greater than the micro-purchase threshold are required to be procured under approved procurement methods. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
Federal Program Affected Program Name: COVID-19: Emergency Connectivity Fund (ECF) Program Assistance Listing Number: 32.009 Pass-Through Entity: N/A ? Direct Award Federal Agency: Federal Communications Commission Criteria or Specific Requirements In accordance with 2 CFR ?200.214 of the Uniform Guidance, non-Federal entities must verify that vendors are nor suspended or debarred prior to entering into covered transactions. Condition The District did not maintain documentation to demonstrate that they verified whether a vendor was suspended or debarred prior to entering into a covered transaction. Cause The condition identified appears to be due to lack of sufficient internal controls to ensure that program requirements are met.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 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. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 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. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 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. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 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. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
See Schedule of Findings and Questioned Costs for chart/table 2022-005: Suspension and Debarment (Significant Deficiency) Criteria: The Authority must design internal controls to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Per 2 CFR 200.214, non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Covered transactions include contracts for goods and services awarded under a nonprocurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., sub-awards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215. OMB Circular A-102 (2 CFR Part 180) requires that recipients ?shall comply with the nonprocurement debarment and suspension common rule implementing Executive Orders 12549 and 12689, Debarment and Suspension.? Condition/context: During the completion of the fiscal year 2021 audit, it was identified that the Authority did not have an internal control system in place to review suspension and debarment on funding decisions made for any purpose other than grant awards. In January 2022, the Authority rectified the deficiency and established a control system. However, proper controls were not in place for the first six months of the fiscal year under audit. For three out of seven vendors selected for testing with purchases greater than $25,000, we determined that the Authority had failed to review two of the vendors (non-grant recipients) for suspension and debarment. However, we independently verified the two vendors were not suspended or debarred. Cause: The Authority was not aware that suspension and debarment requirements applied to all covered transactions. Effect: If the Authority is not verifying that vendors with which it contracts are neither suspended nor debarred, it is possible that the Authority could contract with a vendor that is suspended or debarred, in which case the Authority may be required to return the funds expended to that vendor to the U.S. Department of Energy. Questioned costs: $0 Identification as a repeat finding: Yes; see prior-year finding 2021-003. Recommendation: As the Authority expanded its internal control policies and procedures related to suspension and debarment for grant awards to all covered transactions, we recommend continued compliance with the established policies and procedures. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 QUESTIONED COSTS N/A CONDITION The following errors were noted during testing of allowable costs, activities and procurement: ? For 1 of 3 vendors tested for procurement, only 1 quote was available for review. ? Vendors were not evaluated for suspension or debarment prior to purchases being made. ? For 3 of 12 disbursements tested, although the purchases are allowable under the grants, the purchases were not included in the grant budgets submitted to the Arizona Department of Education. Amended budgets were submitted on August 31, 2022. CRITERIA In accordance with 2 CFR 200.320 Methods of Procurement to be Followed, The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. 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. In accordance with 2 CFR 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. In accordance with 2CFR 200.403 Factors Affecting Allowability of Costs, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: a. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c. Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d. Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e. Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f. Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also ? 200.306(b). g. Be adequately documented. See also ?? 200.300 through 200.309 of this part. h. Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3). In accordance with OMB Compliance Supplement, Part 6 ? Internal Control, non-Federal entities receiving Federal awards establish and maintain internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. EFFECT Program requirements were not complied with. The School may not have received the best pricing for goods or services. CAUSE Procurement procedures were not established to ensure compliance with federal regulations, including retention of quotes from an adequate number of vendors and suspension and debarment requirements. Additionally, internal controls were not designed appropriately to ensure that expenditures charged to the grant were periodically compared to the grant budgets to determine if budget amendments should be submitted. RECOMMENDATION AND BENEFIT A control system should be developed and implemented to monitor when federal expenditures require procurement, that all documentation is obtained and retained and vendors are reviewed for suspension and debarment. Additionally, internal controls should be modified to periodically compare actual expenditures under the grant with submitted budgets. This will help ensure that program requirements are complied with, the School only uses vendors that have not been suspended or debarred and budget amendments are submitted timely. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 QUESTIONED COSTS N/A CONDITION The following errors were noted during testing of allowable costs, activities and procurement: ? For 1 of 3 vendors tested for procurement, only 1 quote was available for review. ? Vendors were not evaluated for suspension or debarment prior to purchases being made. ? For 3 of 12 disbursements tested, although the purchases are allowable under the grants, the purchases were not included in the grant budgets submitted to the Arizona Department of Education. Amended budgets were submitted on August 31, 2022. CRITERIA In accordance with 2 CFR 200.320 Methods of Procurement to be Followed, The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. 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. In accordance with 2 CFR 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. In accordance with 2CFR 200.403 Factors Affecting Allowability of Costs, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: a. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c. Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d. Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e. Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f. Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also ? 200.306(b). g. Be adequately documented. See also ?? 200.300 through 200.309 of this part. h. Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3). In accordance with OMB Compliance Supplement, Part 6 ? Internal Control, non-Federal entities receiving Federal awards establish and maintain internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. EFFECT Program requirements were not complied with. The School may not have received the best pricing for goods or services. CAUSE Procurement procedures were not established to ensure compliance with federal regulations, including retention of quotes from an adequate number of vendors and suspension and debarment requirements. Additionally, internal controls were not designed appropriately to ensure that expenditures charged to the grant were periodically compared to the grant budgets to determine if budget amendments should be submitted. RECOMMENDATION AND BENEFIT A control system should be developed and implemented to monitor when federal expenditures require procurement, that all documentation is obtained and retained and vendors are reviewed for suspension and debarment. Additionally, internal controls should be modified to periodically compare actual expenditures under the grant with submitted budgets. This will help ensure that program requirements are complied with, the School only uses vendors that have not been suspended or debarred and budget amendments are submitted timely. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
See Schedule of Findings and Questioned Costs for chart/table. Condition During our audit, we tested a non statistical sample of seven subawards and found no evidence indicating that program personnel verified whether any of the contractors were not federally suspended or debarred. Criteria According to 2 CFR 200.214, regulations restrict awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from, ineligible from, or ineligible for participation in federal assistance programs or activities. Therefore, verification is required that either checks the System for Award Management (SAM), an official website for the U.S. Government, collects a certification from the contractor, or adds a clause or condition to the contract. Effect Without evaluating the contractors? status on the SAM before executing agreements, the State may pass through federal funding to ineligible entities. Cause and View of Responsible Officials Program personnel responsible for procurement indicated that a review for the federal SAM website was performed prior to the execution of the contract, however, no formal documentation of the review was retained. Recommendation We recommend that program management retain evidence of the suspension and debarment review, including who performed the procedure and the date performed, prior to entering into the agreement.
Substance Abuse and Mental Health Services ? Projects of Regional and National Significance, Assistance Listing Number 93.243, U.S. Department of Health and Human Services, Award Number 1H79TI084470-01, Award Year 2022 Criteria or Specific Requirement ? Procurement, Suspension, and Debarment ? 2 CFR ? 200.317?.327; 2 CFR ? 200.214 Condition ? Red Rock is required to have and use documented procurement procedures, consistent with federal, state, and local laws and regulations, for the acquisition of property or services required under a federal award or subaward and determine an entity is not suspended or debarred before awarding a contract. Questioned Costs ? None Context ? Two purchases exceeded the small purchase threshold for this program during 2022. Neither had documentation supporting price or rate quotations and neither had documentation that procedures were performed to ensure vendors were not debarred, suspended, or otherwise excluded from participation in federal assistance programs or activities. Effect ? Red Rock?s procurements were not conducted in accordance with federal laws and regulations and Red Rock?s procurement policy does not meet federal requirements. In addition, the entity did not have a policy to check suspension and debarment for contracts using federal awards. Cause ? Red Rock?s procurement procedures are not tailored to include consideration of the Uniform Guidance, including methods of procurement to be followed, the thresholds at which certain procedures are necessary, provisions regarding conflicts of interest, and procedures to ensure vendors are not debarred or suspended from participation in federal assistance programs or activities. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? Red Rock should revise its procurement policy to ensure procurements are conducted in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding, and changes to Red Rock?s procurement policy are being implemented during FY 2023. Purchasing staff will be trained on federal procurement requirements and will be provided a copy of the new policy.
Substance Abuse and Mental Health Services ? Projects of Regional and National Significance, Assistance Listing Number 93.243, U.S. Department of Health and Human Services, Award Number 1H79TI084470-01, Award Year 2022 Criteria or Specific Requirement ? Procurement, Suspension, and Debarment ? 2 CFR ? 200.317?.327; 2 CFR ? 200.214 Condition ? Red Rock is required to have and use documented procurement procedures, consistent with federal, state, and local laws and regulations, for the acquisition of property or services required under a federal award or subaward and determine an entity is not suspended or debarred before awarding a contract. Questioned Costs ? None Context ? Two purchases exceeded the small purchase threshold for this program during 2022. Neither had documentation supporting price or rate quotations and neither had documentation that procedures were performed to ensure vendors were not debarred, suspended, or otherwise excluded from participation in federal assistance programs or activities. Effect ? Red Rock?s procurements were not conducted in accordance with federal laws and regulations and Red Rock?s procurement policy does not meet federal requirements. In addition, the entity did not have a policy to check suspension and debarment for contracts using federal awards. Cause ? Red Rock?s procurement procedures are not tailored to include consideration of the Uniform Guidance, including methods of procurement to be followed, the thresholds at which certain procedures are necessary, provisions regarding conflicts of interest, and procedures to ensure vendors are not debarred or suspended from participation in federal assistance programs or activities. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? Red Rock should revise its procurement policy to ensure procurements are conducted in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding, and changes to Red Rock?s procurement policy are being implemented during FY 2023. Purchasing staff will be trained on federal procurement requirements and will be provided a copy of the new policy.
2022-003 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Department Of Agriculture Passed Through the South Dakota Department of Education Child Nutrition Cluster (CNC) Federal Financial Assistance Listing 10.553 School Breakfast Program (SBP) Federal Financial Assistance Listing 10.555 National School Lunch Program (NSLP) Federal Financial Assistance Listing 10.559 Summer Food Service Program For Children (SFSP) 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls over Compliance and Non-Compliance Criteria: 2 CFR section 200.214, sets forth the criteria for suspension and debarment requirements. Condition: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the School District had verified that the vendors were not suspended or debarred prior to purchases. Cause: Vendors are not being checked for suspension and debarment consistently prior to covered transactions when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: These errors could result in payment to suspended or debarred vendors. Questioned Costs: None. Context/Sampling: For HEERF, one of the 3 tested vendors did not have documented suspension and debarment verification with a total population of 4 vendors. For the Child Nutrition Cluster testing, one of the 7 tested vendors did not have documented suspension and debarment verification with a total population of 55 vendors. Repeat Finding from Prior Year(s): Yes, Finding 2021-005. Recommendation: We recommend that all purchases with amounts expected to go over $25,000 be vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transactions. Views of Responsible Officials: Management agrees with the finding.
2022-003 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Department Of Agriculture Passed Through the South Dakota Department of Education Child Nutrition Cluster (CNC) Federal Financial Assistance Listing 10.553 School Breakfast Program (SBP) Federal Financial Assistance Listing 10.555 National School Lunch Program (NSLP) Federal Financial Assistance Listing 10.559 Summer Food Service Program For Children (SFSP) 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls over Compliance and Non-Compliance Criteria: 2 CFR section 200.214, sets forth the criteria for suspension and debarment requirements. Condition: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the School District had verified that the vendors were not suspended or debarred prior to purchases. Cause: Vendors are not being checked for suspension and debarment consistently prior to covered transactions when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: These errors could result in payment to suspended or debarred vendors. Questioned Costs: None. Context/Sampling: For HEERF, one of the 3 tested vendors did not have documented suspension and debarment verification with a total population of 4 vendors. For the Child Nutrition Cluster testing, one of the 7 tested vendors did not have documented suspension and debarment verification with a total population of 55 vendors. Repeat Finding from Prior Year(s): Yes, Finding 2021-005. Recommendation: We recommend that all purchases with amounts expected to go over $25,000 be vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transactions. Views of Responsible Officials: Management agrees with the finding.
2022-003 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Department Of Agriculture Passed Through the South Dakota Department of Education Child Nutrition Cluster (CNC) Federal Financial Assistance Listing 10.553 School Breakfast Program (SBP) Federal Financial Assistance Listing 10.555 National School Lunch Program (NSLP) Federal Financial Assistance Listing 10.559 Summer Food Service Program For Children (SFSP) 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls over Compliance and Non-Compliance Criteria: 2 CFR section 200.214, sets forth the criteria for suspension and debarment requirements. Condition: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the School District had verified that the vendors were not suspended or debarred prior to purchases. Cause: Vendors are not being checked for suspension and debarment consistently prior to covered transactions when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: These errors could result in payment to suspended or debarred vendors. Questioned Costs: None. Context/Sampling: For HEERF, one of the 3 tested vendors did not have documented suspension and debarment verification with a total population of 4 vendors. For the Child Nutrition Cluster testing, one of the 7 tested vendors did not have documented suspension and debarment verification with a total population of 55 vendors. Repeat Finding from Prior Year(s): Yes, Finding 2021-005. Recommendation: We recommend that all purchases with amounts expected to go over $25,000 be vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transactions. Views of Responsible Officials: Management agrees with the finding.
2022-003 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Department Of Agriculture Passed Through the South Dakota Department of Education Child Nutrition Cluster (CNC) Federal Financial Assistance Listing 10.553 School Breakfast Program (SBP) Federal Financial Assistance Listing 10.555 National School Lunch Program (NSLP) Federal Financial Assistance Listing 10.559 Summer Food Service Program For Children (SFSP) 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls over Compliance and Non-Compliance Criteria: 2 CFR section 200.214, sets forth the criteria for suspension and debarment requirements. Condition: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the School District had verified that the vendors were not suspended or debarred prior to purchases. Cause: Vendors are not being checked for suspension and debarment consistently prior to covered transactions when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: These errors could result in payment to suspended or debarred vendors. Questioned Costs: None. Context/Sampling: For HEERF, one of the 3 tested vendors did not have documented suspension and debarment verification with a total population of 4 vendors. For the Child Nutrition Cluster testing, one of the 7 tested vendors did not have documented suspension and debarment verification with a total population of 55 vendors. Repeat Finding from Prior Year(s): Yes, Finding 2021-005. Recommendation: We recommend that all purchases with amounts expected to go over $25,000 be vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transactions. Views of Responsible Officials: Management agrees with the finding.
2022-003 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Department Of Agriculture Passed Through the South Dakota Department of Education Child Nutrition Cluster (CNC) Federal Financial Assistance Listing 10.553 School Breakfast Program (SBP) Federal Financial Assistance Listing 10.555 National School Lunch Program (NSLP) Federal Financial Assistance Listing 10.559 Summer Food Service Program For Children (SFSP) 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls over Compliance and Non-Compliance Criteria: 2 CFR section 200.214, sets forth the criteria for suspension and debarment requirements. Condition: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the School District had verified that the vendors were not suspended or debarred prior to purchases. Cause: Vendors are not being checked for suspension and debarment consistently prior to covered transactions when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: These errors could result in payment to suspended or debarred vendors. Questioned Costs: None. Context/Sampling: For HEERF, one of the 3 tested vendors did not have documented suspension and debarment verification with a total population of 4 vendors. For the Child Nutrition Cluster testing, one of the 7 tested vendors did not have documented suspension and debarment verification with a total population of 55 vendors. Repeat Finding from Prior Year(s): Yes, Finding 2021-005. Recommendation: We recommend that all purchases with amounts expected to go over $25,000 be vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transactions. Views of Responsible Officials: Management 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): 09-344 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency 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 the one vendor in our statistically valid sample, the Town received a certification of suspension and debarment status dated November 1, 2021. The previous certification received from the vendor was dated January 21, 2020. Certifications (or other methods of verification) should be received/performed every 12 months at a minimum. Questioned Costs: None. Cause: Procedures were not in place to timely document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. 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: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Pass-Through Agency: Massachusetts Department of Elementary & Secondary Education Pass-Through Number(s): 09-344 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency 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 the one vendor in our statistically valid sample, the Town received a certification of suspension and debarment status dated November 1, 2021. The previous certification received from the vendor was dated January 21, 2020. Certifications (or other methods of verification) should be received/performed every 12 months at a minimum. Questioned Costs: None. Cause: Procedures were not in place to timely document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. 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.