Criteria: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.318 specifies that a 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. The nonfederal entity’s documented procurement procedures must conform to the procurement standards. Condition: The Association does not have a formal procurement policy, including suspension and debarment, in compliance with Uniform Guidance. Questioned costs: None. Context: During the course of our audit, it was noted that the procurement policy in place at the Association is not in compliance with Uniform Guidance. There is also a lack of a suspension and debarment policy. Without a procurement or suspension and debarment policy, there is no clear guidance or framework for procurement activities or suspension and debarment, which increases the risk of non-compliance with applicable laws and regulations, as well as the risk of fraud, waste, and abuse. Cause: The root cause of this finding is the lack of a formal procurement policy and suspension and debarment policy in compliance with Uniform Guidance. This may be due to a lack of awareness of the importance of such policies, or a lack of resources to develop and implement such a policy. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of policies over these compliance requirements provides an opportunity for noncompliance. Recommendation: To address this finding, we recommend that the Association develop and implement a formal procurement policy that includes the following elements: 1. Procurement objectives and principles. 2. Roles and responsibilities of procurement personnel. 3. Procurement procedures, including vendor selection, contract award, and conflict of interest management. 4. Procurement documentation requirements. 5. Procurement monitoring and reporting requirements. 6. Verification and documentation procedures that covered transactions are not made to parties that are suspended or debarred. Views of responsible officials: There is no disagreement with the audit finding and will take the following actions: 1. Develop and implement a formal procurement policy by July 31, 2024 2. Assign responsibility for procurement policy development and implementation to Talana Lay, Board Secretary and Treasurer. 3. Provide training to procurement personnel on the new policy and procedures.
Finding Reference: 2023-002 – Procurement Policies and Procedures Federal Agency: U.S Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities - ALN# 10.760 Compliance Requirement: Procurement, suspension, and debarment Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The Authority does not have any documented procurement procedures. However, during our testing of compliance with procurement guidelines, no further deviations from federal guidelines were noted. Cause and Effect: The Authority was unacquainted with general procurement standards of the Uniform Grant Guidance. Without documented procurement procedures, it is difficult for the Authority to ensure compliance with relevant compliance requirements. Questioned Cost: None Identification of Repeat Finding: No Recommendation: The Authority should establish documented procedures related to federal procurement. Views of Responsible Officials: This was first brought to the Authority’s attention in the current year. At such a late date in the federal project that has been in the works for multiple years, the Authority determined established procurement procedures would not be written and approved. The Authority did not make this decision in haste. The Authority met compliance guidelines for the procedures of items during the project. What we lack is an approved written document, which at this time is something we do not have the resources to undertake.
Criteria: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.318 specifies that a 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. The nonfederal entity’s documented procurement procedures must conform to the procurement standards. Condition: The Association does not have a formal procurement policy, including suspension and debarment, in compliance with Uniform Guidance. Questioned costs: None. Context: During the course of our audit, it was noted that the procurement policy in place at the Association is not in compliance with Uniform Guidance. There is also a lack of a suspension and debarment policy. Without a procurement or suspension and debarment policy, there is no clear guidance or framework for procurement activities or suspension and debarment, which increases the risk of non-compliance with applicable laws and regulations, as well as the risk of fraud, waste, and abuse. Cause: The root cause of this finding is the lack of a formal procurement policy and suspension and debarment policy in compliance with Uniform Guidance. This may be due to a lack of awareness of the importance of such policies, or a lack of resources to develop and implement such a policy. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of policies over these compliance requirements provides an opportunity for noncompliance. Recommendation: To address this finding, we recommend that the Association develop and implement a formal procurement policy that includes the following elements: 1. Procurement objectives and principles. 2. Roles and responsibilities of procurement personnel. 3. Procurement procedures, including vendor selection, contract award, and conflict of interest management. 4. Procurement documentation requirements. 5. Procurement monitoring and reporting requirements. 6. Verification and documentation procedures that covered transactions are not made to parties that are suspended or debarred. Views of responsible officials: There is no disagreement with the audit finding and will take the following actions: 1. Develop and implement a formal procurement policy by July 31, 2024 2. Assign responsibility for procurement policy development and implementation to Talana Lay, Board Secretary and Treasurer. 3. Provide training to procurement personnel on the new policy and procedures.
Criteria: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.318 specifies that a 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. The nonfederal entity’s documented procurement procedures must conform to the procurement standards. Condition: The Association does not have a formal procurement policy, including suspension and debarment, in compliance with Uniform Guidance. Questioned costs: None. Context: During the course of our audit, it was noted that the procurement policy in place at the Association is not in compliance with Uniform Guidance. There is also a lack of a suspension and debarment policy. Without a procurement or suspension and debarment policy, there is no clear guidance or framework for procurement activities or suspension and debarment, which increases the risk of non-compliance with applicable laws and regulations, as well as the risk of fraud, waste, and abuse. Cause: The root cause of this finding is the lack of a formal procurement policy and suspension and debarment policy in compliance with Uniform Guidance. This may be due to a lack of awareness of the importance of such policies, or a lack of resources to develop and implement such a policy. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of policies over these compliance requirements provides an opportunity for noncompliance. Recommendation: To address this finding, we recommend that the Association develop and implement a formal procurement policy that includes the following elements: 1. Procurement objectives and principles. 2. Roles and responsibilities of procurement personnel. 3. Procurement procedures, including vendor selection, contract award, and conflict of interest management. 4. Procurement documentation requirements. 5. Procurement monitoring and reporting requirements. 6. Verification and documentation procedures that covered transactions are not made to parties that are suspended or debarred. Views of responsible officials: There is no disagreement with the audit finding and will take the following actions: 1. Develop and implement a formal procurement policy by July 31, 2024 2. Assign responsibility for procurement policy development and implementation to Talana Lay, Board Secretary and Treasurer. 3. Provide training to procurement personnel on the new policy and procedures.
Criteria: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.318 specifies that a 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. The nonfederal entity’s documented procurement procedures must conform to the procurement standards. Condition: The Association does not have a formal procurement policy, including suspension and debarment, in compliance with Uniform Guidance. Questioned costs: None. Context: During the course of our audit, it was noted that the procurement policy in place at the Association is not in compliance with Uniform Guidance. There is also a lack of a suspension and debarment policy. Without a procurement or suspension and debarment policy, there is no clear guidance or framework for procurement activities or suspension and debarment, which increases the risk of non-compliance with applicable laws and regulations, as well as the risk of fraud, waste, and abuse. Cause: The root cause of this finding is the lack of a formal procurement policy and suspension and debarment policy in compliance with Uniform Guidance. This may be due to a lack of awareness of the importance of such policies, or a lack of resources to develop and implement such a policy. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of policies over these compliance requirements provides an opportunity for noncompliance. Recommendation: To address this finding, we recommend that the Association develop and implement a formal procurement policy that includes the following elements: 1. Procurement objectives and principles. 2. Roles and responsibilities of procurement personnel. 3. Procurement procedures, including vendor selection, contract award, and conflict of interest management. 4. Procurement documentation requirements. 5. Procurement monitoring and reporting requirements. 6. Verification and documentation procedures that covered transactions are not made to parties that are suspended or debarred. Views of responsible officials: There is no disagreement with the audit finding and will take the following actions: 1. Develop and implement a formal procurement policy by July 31, 2024 2. Assign responsibility for procurement policy development and implementation to Talana Lay, Board Secretary and Treasurer. 3. Provide training to procurement personnel on the new policy and procedures.
Criteria or specific requirement (including statutory, regulatory, or other citation): Procurement. The District should follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Condition: The District did not follow the small purchase method for procurement that is required for purchases made between $10,000 and $250,000. This method requires that price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b). Questioned Costs: None. Context: There was only one purchase over $10,000 made with these grants funds during the fiscal year and the required procurement method was not followed. Effect: The District did not comply with the required procurement standard. Cause: This purchase had to be made quickly so the District used their perferred vendor. Recommendation: We recommend that care is taken to ensure that all the procurement requirements are followed based on the amount of the purchase being made with the federal funds. Management's response: We will follow the procurement standard when not in urgent situations for the product or service we are seeking.
Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. procedure due to the turnover in the purchasing agent position verification could not be located. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select “Search” from the header menu from any page on SAM.gov 2) In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. procedure due to the turnover in the purchasing agent position verification could not be located. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select “Search” from the header menu from any page on SAM.gov 2) In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. procedure due to the turnover in the purchasing agent position verification could not be located. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select “Search” from the header menu from any page on SAM.gov 2) In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. procedure due to the turnover in the purchasing agent position verification could not be located. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select “Search” from the header menu from any page on SAM.gov 2) In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Federal Agency: U.S. Department of Education, passed through the State of Alaska, Department of Education and Early Development Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, and 10.582 Award Number: None (10.553); None and FD 23.KGSD.01 (10.555); None (10.559), and FF 23.KGSD.01 and FF 23.KGSD.02 (10.582) Award Year: 2023 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: The District was unable to provide adequate supporting documentation showing that contractors were selected using an adequate procurement process. Condition and Context: Procurement standards required by 2 CFR 200.318 were not followed. During our testing of procurement, we determined that management did not conduct an annual cost study or formal procurement process for food and supplies to be used in the food service program. Cause: Lack of internal control over procurement requirements. Effect: Failure to follow 2 CRF 200.318 could result in loss of federal funding. Also, the District risks overpaying for food and supplies by not following procurement standards. Questioned Costs: None noted. Repeat finding: This is not a repeat finding, as such it appears to be an isolated instance. Recommendation: We recommend that management complies with all procurement requirements applicable to 2 CFR 200.318 to ensure the District’s compliance with such requirements. Management Response: Management agrees with this finding, see Corrective Action Plan.
Federal Agency: U.S. Department of Education, passed through the State of Alaska, Department of Education and Early Development Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, and 10.582 Award Number: None (10.553); None and FD 23.KGSD.01 (10.555); None (10.559), and FF 23.KGSD.01 and FF 23.KGSD.02 (10.582) Award Year: 2023 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: The District was unable to provide adequate supporting documentation showing that contractors were selected using an adequate procurement process. Condition and Context: Procurement standards required by 2 CFR 200.318 were not followed. During our testing of procurement, we determined that management did not conduct an annual cost study or formal procurement process for food and supplies to be used in the food service program. Cause: Lack of internal control over procurement requirements. Effect: Failure to follow 2 CRF 200.318 could result in loss of federal funding. Also, the District risks overpaying for food and supplies by not following procurement standards. Questioned Costs: None noted. Repeat finding: This is not a repeat finding, as such it appears to be an isolated instance. Recommendation: We recommend that management complies with all procurement requirements applicable to 2 CFR 200.318 to ensure the District’s compliance with such requirements. Management Response: Management agrees with this finding, see Corrective Action Plan.
Federal Agency: U.S. Department of Education, passed through the State of Alaska, Department of Education and Early Development Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, and 10.582 Award Number: None (10.553); None and FD 23.KGSD.01 (10.555); None (10.559), and FF 23.KGSD.01 and FF 23.KGSD.02 (10.582) Award Year: 2023 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: The District was unable to provide adequate supporting documentation showing that contractors were selected using an adequate procurement process. Condition and Context: Procurement standards required by 2 CFR 200.318 were not followed. During our testing of procurement, we determined that management did not conduct an annual cost study or formal procurement process for food and supplies to be used in the food service program. Cause: Lack of internal control over procurement requirements. Effect: Failure to follow 2 CRF 200.318 could result in loss of federal funding. Also, the District risks overpaying for food and supplies by not following procurement standards. Questioned Costs: None noted. Repeat finding: This is not a repeat finding, as such it appears to be an isolated instance. Recommendation: We recommend that management complies with all procurement requirements applicable to 2 CFR 200.318 to ensure the District’s compliance with such requirements. Management Response: Management agrees with this finding, see Corrective Action Plan.
Federal Agency: U.S. Department of Education, passed through the State of Alaska, Department of Education and Early Development Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, and 10.582 Award Number: None (10.553); None and FD 23.KGSD.01 (10.555); None (10.559), and FF 23.KGSD.01 and FF 23.KGSD.02 (10.582) Award Year: 2023 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: The District was unable to provide adequate supporting documentation showing that contractors were selected using an adequate procurement process. Condition and Context: Procurement standards required by 2 CFR 200.318 were not followed. During our testing of procurement, we determined that management did not conduct an annual cost study or formal procurement process for food and supplies to be used in the food service program. Cause: Lack of internal control over procurement requirements. Effect: Failure to follow 2 CRF 200.318 could result in loss of federal funding. Also, the District risks overpaying for food and supplies by not following procurement standards. Questioned Costs: None noted. Repeat finding: This is not a repeat finding, as such it appears to be an isolated instance. Recommendation: We recommend that management complies with all procurement requirements applicable to 2 CFR 200.318 to ensure the District’s compliance with such requirements. Management Response: Management agrees with this finding, see Corrective Action Plan.
Federal Agency: U.S. Department of Education, passed through the State of Alaska, Department of Education and Early Development Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, and 10.582 Award Number: None (10.553); None and FD 23.KGSD.01 (10.555); None (10.559), and FF 23.KGSD.01 and FF 23.KGSD.02 (10.582) Award Year: 2023 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: The District was unable to provide adequate supporting documentation showing that contractors were selected using an adequate procurement process. Condition and Context: Procurement standards required by 2 CFR 200.318 were not followed. During our testing of procurement, we determined that management did not conduct an annual cost study or formal procurement process for food and supplies to be used in the food service program. Cause: Lack of internal control over procurement requirements. Effect: Failure to follow 2 CRF 200.318 could result in loss of federal funding. Also, the District risks overpaying for food and supplies by not following procurement standards. Questioned Costs: None noted. Repeat finding: This is not a repeat finding, as such it appears to be an isolated instance. Recommendation: We recommend that management complies with all procurement requirements applicable to 2 CFR 200.318 to ensure the District’s compliance with such requirements. Management Response: Management agrees with this finding, see Corrective Action Plan.
Federal Agency: U.S. Department of Education, passed through the State of Alaska, Department of Education and Early Development Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, and 10.582 Award Number: None (10.553); None and FD 23.KGSD.01 (10.555); None (10.559), and FF 23.KGSD.01 and FF 23.KGSD.02 (10.582) Award Year: 2023 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: The District was unable to provide adequate supporting documentation showing that contractors were selected using an adequate procurement process. Condition and Context: Procurement standards required by 2 CFR 200.318 were not followed. During our testing of procurement, we determined that management did not conduct an annual cost study or formal procurement process for food and supplies to be used in the food service program. Cause: Lack of internal control over procurement requirements. Effect: Failure to follow 2 CRF 200.318 could result in loss of federal funding. Also, the District risks overpaying for food and supplies by not following procurement standards. Questioned Costs: None noted. Repeat finding: This is not a repeat finding, as such it appears to be an isolated instance. Recommendation: We recommend that management complies with all procurement requirements applicable to 2 CFR 200.318 to ensure the District’s compliance with such requirements. Management Response: Management agrees with this finding, see Corrective Action Plan.
Federal Agency: U.S. Department of Education, passed through the State of Alaska, Department of Education and Early Development Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, and 10.582 Award Number: None (10.553); None and FD 23.KGSD.01 (10.555); None (10.559), and FF 23.KGSD.01 and FF 23.KGSD.02 (10.582) Award Year: 2023 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: The District was unable to provide adequate supporting documentation showing that contractors were selected using an adequate procurement process. Condition and Context: Procurement standards required by 2 CFR 200.318 were not followed. During our testing of procurement, we determined that management did not conduct an annual cost study or formal procurement process for food and supplies to be used in the food service program. Cause: Lack of internal control over procurement requirements. Effect: Failure to follow 2 CRF 200.318 could result in loss of federal funding. Also, the District risks overpaying for food and supplies by not following procurement standards. Questioned Costs: None noted. Repeat finding: This is not a repeat finding, as such it appears to be an isolated instance. Recommendation: We recommend that management complies with all procurement requirements applicable to 2 CFR 200.318 to ensure the District’s compliance with such requirements. Management Response: Management agrees with this finding, see Corrective Action Plan.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 AND – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2023-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension, and Debarment Requirements Criteria – 2 CFR § 180.425-430 and 2 CFR § 200.318-327 requires Independent School District No. 12 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, suspension, and debarment requirements applicable to the special education cluster and coronavirus state and local fiscal recovery funds federal programs. Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its special education cluster and coronavirus state and local fiscal recovery funds federal programs to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Context – For three of three vendors exceeding the micro-purchase threshold, the District did not document procurement policy and Uniform Guidance requirements related to methods of procurement and a proper documentation of suspension and debarment testing was not maintained to ensure compliance with this requirement in the current year. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – This was an oversight by district personnel, due in part, to staff turnover. Effect – Noncompliance with procurement, suspension, and debarment requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to procurement, suspension, and debarment for the special education cluster and coronavirus state and local fiscal recovery funds federal programs. Internal controls over compliance should be in place to ensure compliance with federal procurement procedures, including awarding and documenting contracts based on sealed bids or quotations for the purchase of goods or services exceeding applicable federal dollar thresholds. Internal controls over compliance should also include verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District intends to review its policies and procedures relating to procurement, suspension, and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 AND – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2023-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension, and Debarment Requirements Criteria – 2 CFR § 180.425-430 and 2 CFR § 200.318-327 requires Independent School District No. 12 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, suspension, and debarment requirements applicable to the special education cluster and coronavirus state and local fiscal recovery funds federal programs. Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its special education cluster and coronavirus state and local fiscal recovery funds federal programs to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Context – For three of three vendors exceeding the micro-purchase threshold, the District did not document procurement policy and Uniform Guidance requirements related to methods of procurement and a proper documentation of suspension and debarment testing was not maintained to ensure compliance with this requirement in the current year. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – This was an oversight by district personnel, due in part, to staff turnover. Effect – Noncompliance with procurement, suspension, and debarment requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to procurement, suspension, and debarment for the special education cluster and coronavirus state and local fiscal recovery funds federal programs. Internal controls over compliance should be in place to ensure compliance with federal procurement procedures, including awarding and documenting contracts based on sealed bids or quotations for the purchase of goods or services exceeding applicable federal dollar thresholds. Internal controls over compliance should also include verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District intends to review its policies and procedures relating to procurement, suspension, and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 AND – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2023-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension, and Debarment Requirements Criteria – 2 CFR § 180.425-430 and 2 CFR § 200.318-327 requires Independent School District No. 12 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, suspension, and debarment requirements applicable to the special education cluster and coronavirus state and local fiscal recovery funds federal programs. Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its special education cluster and coronavirus state and local fiscal recovery funds federal programs to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Context – For three of three vendors exceeding the micro-purchase threshold, the District did not document procurement policy and Uniform Guidance requirements related to methods of procurement and a proper documentation of suspension and debarment testing was not maintained to ensure compliance with this requirement in the current year. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – This was an oversight by district personnel, due in part, to staff turnover. Effect – Noncompliance with procurement, suspension, and debarment requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to procurement, suspension, and debarment for the special education cluster and coronavirus state and local fiscal recovery funds federal programs. Internal controls over compliance should be in place to ensure compliance with federal procurement procedures, including awarding and documenting contracts based on sealed bids or quotations for the purchase of goods or services exceeding applicable federal dollar thresholds. Internal controls over compliance should also include verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District intends to review its policies and procedures relating to procurement, suspension, and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 AND – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2023-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension, and Debarment Requirements Criteria – 2 CFR § 180.425-430 and 2 CFR § 200.318-327 requires Independent School District No. 12 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, suspension, and debarment requirements applicable to the special education cluster and coronavirus state and local fiscal recovery funds federal programs. Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its special education cluster and coronavirus state and local fiscal recovery funds federal programs to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Context – For three of three vendors exceeding the micro-purchase threshold, the District did not document procurement policy and Uniform Guidance requirements related to methods of procurement and a proper documentation of suspension and debarment testing was not maintained to ensure compliance with this requirement in the current year. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – This was an oversight by district personnel, due in part, to staff turnover. Effect – Noncompliance with procurement, suspension, and debarment requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to procurement, suspension, and debarment for the special education cluster and coronavirus state and local fiscal recovery funds federal programs. Internal controls over compliance should be in place to ensure compliance with federal procurement procedures, including awarding and documenting contracts based on sealed bids or quotations for the purchase of goods or services exceeding applicable federal dollar thresholds. Internal controls over compliance should also include verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District intends to review its policies and procedures relating to procurement, suspension, and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 AND – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2023-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension, and Debarment Requirements Criteria – 2 CFR § 180.425-430 and 2 CFR § 200.318-327 requires Independent School District No. 12 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, suspension, and debarment requirements applicable to the special education cluster and coronavirus state and local fiscal recovery funds federal programs. Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its special education cluster and coronavirus state and local fiscal recovery funds federal programs to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Context – For three of three vendors exceeding the micro-purchase threshold, the District did not document procurement policy and Uniform Guidance requirements related to methods of procurement and a proper documentation of suspension and debarment testing was not maintained to ensure compliance with this requirement in the current year. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – This was an oversight by district personnel, due in part, to staff turnover. Effect – Noncompliance with procurement, suspension, and debarment requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to procurement, suspension, and debarment for the special education cluster and coronavirus state and local fiscal recovery funds federal programs. Internal controls over compliance should be in place to ensure compliance with federal procurement procedures, including awarding and documenting contracts based on sealed bids or quotations for the purchase of goods or services exceeding applicable federal dollar thresholds. Internal controls over compliance should also include verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District intends to review its policies and procedures relating to procurement, suspension, and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District’s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District’s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District’s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District’s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District’s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
Program: Magnet Schools Assistance (Assistance Listing No. 84.165) Compliance Requirement – Procurement, Suspension and Debarment Finding Type: Material Noncompliance / Material Weakness in Internal Controls over Compliance Criteria: 2 CFR Part 180.300 requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity and its principals, as defined in 2 CFR section 180.995 and agency adopting regulations, are not suspended or debarred or otherwise excluded from participating in the transaction. 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 https://www.sam.gov/ (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. In addition, under 2 CFR 200.318, the non-Federal entity must have and use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. Condition: The Magnet Schools Assistance Program (MSAP) office did not verify that contracted vendors are not suspended or debarred or otherwise excluded from participating in program transactions prior to their participation. In addition, the MSAP Director entered into a contract for services without having the authority to do so, thus circumventing the procurement procedures of the District. Cause: The MSAP office was unaware of the federal requirements related to verifying that contracted vendors are not suspended or debarred or otherwise excluded from participating in program transactions. In addition, it appears that the MSAP Director felt her position provided her the authority to enter into contracts under her program, regardless of standard District procurement procedures. Effect: The failure to verify suspension and debarment can result in entering into prohibited transactions, leading to non-compliance and the loss of program funding. In addition, not following procurement procedures can result in prohibited transactions and the repayment of federal funds used. Auditor’s Recommendations: The MSAP office should familiarize themselves with federal compliance requirements including suspension and debarment. In addition, the MSAP office should ensure all transactions that do not qualify as “small-purchases” be procured by the District Procurement Department. Views of Responsible Official: The MSAP program will undergo specific training related to federal compliance including procurement, suspension and debarment. The District will implement additional monitoring procedures to ensure transactions that do not qualify as “small-purchases” be procured by the District Procurement Department.
2023-003 Procurement; Federal Agency: Department of Health and Human Services; Program: Social Services Research and Demonstration (ALN 93.647); Pass-through Entity: N/A; Federal Assistance Identification Number or Pass-Through Numbers: N/A; Federal Award Years: Year ended June 30, 2023; Type of Finding: Material Weakness in Internal Control over Compliance; Other Matter Compliance Finding; Criteria: 2 CFR 200.303(a) requires that each non-Federal entity must "Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." 2 CFR 200.320 requires that each 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." Condition: While testing the procurement requirement, we were able to test compensating controls, but noted that internal controls were not properly designed over the procurement requirement. Prior to receiving federal funding beginning in August 2022, the program conducted a request for proposal (RFP) process and began contracting with a vendor. When federal funding was obtained, the vendor was not reevaluated in accordance with the Uniform Guidance to ensure the procurement requirements were being met. In addition, we noted UW Health – Madison’s procurement policy documents do not include all of the information that is required by the Uniform Guidance. Cause: Because the vendor was already in place for the program prior to receiving federal funds, management did not recognize the need to reevaluate the vendor under the requirements of the Uniform Guidance. In addition, management also did not recognize the need to include additional information in its procurement policy documents related to the Uniform Guidance. Effect: Without appropriate internal controls, there is an increased risk of noncompliance related to federal funding. Context: We identified and tested one vendor that was direct and material to the program and related to the procurement and suspension and debarment requirements. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.Questioned Costs: None. Repeat Finding?: No; Recommendation: While it was determined that the requirements of the Uniform Guidance were met related to the vendor tested, we suggest that management reevaluate all vendors that were previously used prior to receiving federal funding. In addition, we recommend that management update its procurement policies to incorporate the requirements of the Uniform Guidance. View of responsible officials of the auditee: Management agrees with the finding. See corrective action plan.
Federal Agency: Department of the Treasury, Department of Health and Human Services Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds, Substance Abuse and Mental Health Services Projects of Regional and National Significance Listing Number: 21.027, 93.243 Federal Award Identification Number and Year: H79TI080926, 2023 Pass-Through Agency: City of Hartford, Career Resources Inc. Pass-Through Number: C2212 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None Context: We reviewed the procurement policy and conflict of interest policy of the Organization and noted that the policies do not include the essential compliance elements as outlined in 2 CFR sections 200.318 through 200.326. Cause: Management was unaware of the restrictive requirements of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of the Treasury, Department of Health and Human Services Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds, Substance Abuse and Mental Health Services Projects of Regional and National Significance Listing Number: 21.027, 93.243 Federal Award Identification Number and Year: H79TI080926, 2023 Pass-Through Agency: City of Hartford, Career Resources Inc. Pass-Through Number: C2212 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None Context: We reviewed the procurement policy and conflict of interest policy of the Organization and noted that the policies do not include the essential compliance elements as outlined in 2 CFR sections 200.318 through 200.326. Cause: Management was unaware of the restrictive requirements of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: Department of the Treasury, Department of Health and Human Services Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds, Substance Abuse and Mental Health Services Projects of Regional and National Significance Listing Number: 21.027, 93.243 Federal Award Identification Number and Year: H79TI080926, 2023 Pass-Through Agency: City of Hartford, Career Resources Inc. Pass-Through Number: C2212 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None Context: We reviewed the procurement policy and conflict of interest policy of the Organization and noted that the policies do not include the essential compliance elements as outlined in 2 CFR sections 200.318 through 200.326. Cause: Management was unaware of the restrictive requirements of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: There is no disagreement with the audit finding.
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized a vendor to purchase online learning products without obtaining formal bids and therefore didn’t following the Districts procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased online learning products from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: No Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized a vendor to purchase online learning products without obtaining formal bids and therefore didn’t following the Districts procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased online learning products from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: No Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized a vendor to purchase online learning products without obtaining formal bids and therefore didn’t following the Districts procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased online learning products from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: No Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized a vendor to purchase online learning products without obtaining formal bids and therefore didn’t following the Districts procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased online learning products from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: No Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized a vendor to purchase online learning products without obtaining formal bids and therefore didn’t following the Districts procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased online learning products from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: No Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
2023-003: Written Policy for Debarred, Suspended Vendors Federal Assistance listing Number: 84.371 Compliance Area: Procurement & Suspension & Debarment (I) Type of Finding: Significant Deficiency Questioned Costs: None Criteria: The District should have written standards of conduct in place to verify any entity (vendor) with which the District spends Federal expenditures or conducts business transactions be not debarred, suspended, or otherwise excluded per 2 CFR 200.318(h) and 2 CFR 180. The written standard should address conduct covering conflicts of interest governing the performance of its employees and contractors engaged in the selection, award, and administration of contracts (Uniform Guidance Section 200.318(c) and 45 CFR sections 52.203-13 and 52.203-16). Condition: During our audit, we found that the District did not have written controls in place to ensure that vendors were not suspended, debarred, or included on the list of vendors prior to entering into a contract. Identification as a repeat finding: No. Recommendation: We recommend that the District put written internal controls in place such as using a checklist to ensure Federal funds that pay contractors are not suspended or debarred and adopts a formal policy on procurment for debarment.
Finding 2023-003 Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: United States Department of State Program Titles: Office of Global Women’s Issues Assistance Listing Number: 19.801 Pass-Through Entity: N/A Award Numbers: SLMAQM21CA3275 Award Periods: September 30, 2021 through September 30, 2025 Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326 Internal Controls, require that a non‐Federal entity use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirement identified in 2 CFR Part 200. A nonfederal entity among others must: - Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). - For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition/Context Although the Organization has a procurement policy, and the procedures include the use of a micro purchase threshold of $3,500, small purchases and simplified acquisition thresholds are not clearly identified. As such, the policy does not fully incorporate the procurement standards of the Uniform Guidance including sealed bids, cost or price analysis etc. Cause The Organization's management was not aware that all components including procurement methods of 2 CFR section 200.320 are required to be included in the Organization's procurement policy even if the Organization's procurements would not typically include all procurement methods. Effect The Organization did not ensure that its procurement policy follows the procurement standards set out at 2 CFR Part 200. Questioned Costs Not determinable. Repeat Finding No. Recommendation We recommend the Organization implement measures to ensure that its procurement policy reflect applicable state and local laws and regulations and conform to applicable federal statutes and requirements in 2 CFR Part 200. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
The Christian County Fiscal Court Did Not Have Adequate Controls Over The Procurement, Suspension and Debarment Compliance Requirement On Federal Expenditures Federal Program: Assistance Listing #21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: Information not available Name of Federal Agency and Pass-Thru Agency (if applicable): U.S. Department of Treasury Compliance Requirements: Procurement, Suspension & Debarment Type of Finding: Material Weakness Amount of Questioned Costs: $0 Opinion Modification (if applicable): No COVID Related: Yes The Christian County Fiscal Court failed to implement adequate controls over Procurement, Suspension and Debarment compliance requirements of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF). The disbursement of the SLFRF monies was not handled in the manner prescribed by the county’s administrative code. Three disbursements totaling $1,378,654 were tested and purchase orders were not utilized for any of the three disbursements. The fiscal court also failed to document adequate controls concerning the compliance with suspension and debarment requirements. There was no documentation that suspension and debarment compliance requirements were followed. The county’s contracts with local utilities failed to include suspension and debarment requirements. Additionally, there was no documentation that a search for suspended or debarred parties was performed prior to disbursing the funds to the utilities. The county treasurer was not aware purchase orders were not issued. Preprinted purchase orders for the ARPA (SLFRF) Fund were not available for use. There was a breakdown in the verification process of debarred or suspended parties. Since the fiscal court did not issue purchase orders for the disbursements from the SLFRF monies, amounts spent could have exceeded budgetary restrictions, rendering them void. Additionally, because there was no documented search for suspended or debarred parties, ineligible vendors or contractors could have been utilized putting the county at risk for being held responsible for unallowed or questioned costs. 2 CFR 200.318(a) states “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.” The Christian County Administrative Code section 4.5 states for claims against Christian County “Each claim shall be recorded by date, receipts, and purchase order number and presented to the Fiscal Court at its next meeting.” Additionally, the Department of Local Government (DLG) requires counties to implement a purchase order system which includes issuing purchase orders for all claims expended from the county’s budget. Good internal controls require the use of established procurement policies to ensure that federal disbursements are handled in the manner consistent with the treatment of non-federal disbursements. 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.” Good internal controls dictate documentation be maintained that verifies debarment and suspension regulations have been communicated and followed for vendors or contractors used in federally funded projects. We recommend that the county improve internal controls over federal expenditures to ensure all compliance requirements are followed. This is not a repeat finding from the previous year.
Federal Agency: Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20977/20983 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency of Internal Control over Compliance Criteria or Specific Requirement: The BOE must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Condition: The BOE procurement standards did not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the BOE did not have a policy in conformity with the federal uniform guidance criteria, the BOE did follow Uniform Guidance and was in compliance with the major program. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: The lack of controls over reporting could result in errors of reported data. Repeat Finding: No Recommendation: We recommend that the BOE review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
Federal Agency: Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20977/20983 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency of Internal Control over Compliance Criteria or Specific Requirement: The BOE must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Condition: The BOE procurement standards did not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the BOE did not have a policy in conformity with the federal uniform guidance criteria, the BOE did follow Uniform Guidance and was in compliance with the major program. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: The lack of controls over reporting could result in errors of reported data. Repeat Finding: No Recommendation: We recommend that the BOE review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
Federal Agency: Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20977/20983 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency of Internal Control over Compliance Criteria or Specific Requirement: The BOE must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Condition: The BOE procurement standards did not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the BOE did not have a policy in conformity with the federal uniform guidance criteria, the BOE did follow Uniform Guidance and was in compliance with the major program. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: The lack of controls over reporting could result in errors of reported data. Repeat Finding: No Recommendation: We recommend that the BOE review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
Federal Agency: Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20977/20983 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency of Internal Control over Compliance Criteria or Specific Requirement: The BOE must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Condition: The BOE procurement standards did not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the BOE did not have a policy in conformity with the federal uniform guidance criteria, the BOE did follow Uniform Guidance and was in compliance with the major program. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: The lack of controls over reporting could result in errors of reported data. Repeat Finding: No Recommendation: We recommend that the BOE review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
Federal Agency: Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20977/20983 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency of Internal Control over Compliance Criteria or Specific Requirement: The BOE must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Condition: The BOE procurement standards did not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the BOE did not have a policy in conformity with the federal uniform guidance criteria, the BOE did follow Uniform Guidance and was in compliance with the major program. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: The lack of controls over reporting could result in errors of reported data. Repeat Finding: No Recommendation: We recommend that the BOE review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
FINDING 2023-001 PROCUREMENT SIGNIFICANT DEFICIENCY Federal Program: Charter Schools Program Assistance Listing Numbers: 84.282A Criteria Per 2 CFR 200.318, “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. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §200.317 through 200.327.” Condition The School’s procurement policies do not include wording or procedures to ensure the School is complying with the above standard. Cause A responsible individual is not monitoring Federal regulations to ensure the School’s procurement procedures are properly documented and in line with the regulations. Effect Not documenting these procedures could result in the School completing procurement transactions that are not in compliance with Federal regulations. Recommendation We recommend the School develop a written procurement policy that incorporates the Federal regulations identified above. Views of Responsible Officials and Planned Corrective Actions The School’s Corrective Action Plan is included on page 22