Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
Finding 2023-007: Procurement Federal Programs: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.555 – National School Lunch Program, 10.553 – School Breakfast Program, and 10.559 – Summer Food Service Program under award numbers 22N1099 (Federal Award Year 2022), 22N1199 (Federal Award Year 2022), and 23N1199 (Federal Award Year 2023). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 23-4210-00, 22-4210-00, 22-4210-BT, 23-4210-SC, 23-4220-00, 22-4220-00, 23-4225-00, and 22-4225-00. Special Education Cluster (IDEA) awarded by the U.S. Department of Education under assistance listing numbers 84.173 – Special Education - Preschool Grants (includes COVID-19 funding) and 84.027 – Special Education – Grants to States (includes COVID-19 funding) under award numbers H027A210072 (Federal Award Year 2021), H027X210072 (Federal Award Year 2021), H173X210101 (Federal Award Year 2021), H027A220072 (Federal Award Year 2022), and H173A220101 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 22-4998-PS, 23-4600-00, 22-4998-ID, 23-4620-00, 23-4620-EI, 23-4625-00, and 22-4625-00. Condition: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Criteria: Uniform Grant Guidance (2 CFR 200.318(i)) states procurement records must be maintained in sufficient detail to document the history of the procurement. The records must include, but are not limited to, the rationale for the method of the procurement, the selection of the vendor, and the basis for the price. Uniform Grant Guidance (2 CFR 200.320) also specifies the methods of procurement that must be used based on the dollar value of the procurement. If small purchase procedures are used, the District must obtain a sufficient number of quotes from qualified vendors. Cause: There was turnover at the department of the District responsible for ensuring procurements are made in accordance with state and federal regulations. Additionally, the District’s electronic system of record for procurement is not used consistently. Supporting documents are sometimes kept at individual departments in paper or e-mail. Questioned Cost: None, the expenditures are allowable uses of grant funds. Context: For eight of the eight vendors selected for procurement testing in the IDEA cluster, the District was unable to provide documentation prepared at the time of the procurement action that supported why the vendor was selected and why no competitive bids or quotations were obtained. Once selected for testing, the District was able to prepare memos for seven of the eight vendors supporting why the vendor was selected and that the procurement was exempt from competitive bidding or obtaining quotations from multiple vendors. For the remaining vendor, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. For one of the five vendors selected for procurement testing in the Child Nutrition Cluster, which under federal requirements would be considered a small purchase, the District was unable to determine why the vendor was selected for the procurement opportunity. Recommendation: We recommend the District review its policies and procedures for purchasing goods and services to ensure procurement history is maintained to document compliance with federal regulations and that all support related to why a vendor was selected be maintained centrally. District’s Response: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Potential Effect: Failure to fully comply with federal regulations could result in amounts being considered unallowable by granting agencies. Prior Finding Number: 2022-001
2023-004 – Procurement, Suspension and Debarment Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; Illinois Criminal Justice Information Authority Pass-Through Number(s): 20220246 - 2023; 20220245 - 2023; 822007 - 2023 Award Period: 3/1/22-12/31/23; 3/1/22-12/31/23; 3/1/22-12/31/24; 4/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: CFR § 200.320 indicates the various methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and § 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. § 200.214 Suspension and debarment indicates non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate procurement process. Questioned costs: N/A Context: 5 of 5 vendors selected for procurement testing, did not have documentation showing that the cost had been procured in accordance with the Uniform Guidance. Additionally, 2 of 2 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate procurement, suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: No Recommendation: We recommend the Organization revised its internal controls related to procurement, suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization is in the process of developing a procurement policy and suspension and debarment policies that aligns with Uniform Guidance.
2023-004 – Procurement, Suspension and Debarment Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; Illinois Criminal Justice Information Authority Pass-Through Number(s): 20220246 - 2023; 20220245 - 2023; 822007 - 2023 Award Period: 3/1/22-12/31/23; 3/1/22-12/31/23; 3/1/22-12/31/24; 4/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: CFR § 200.320 indicates the various methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and § 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. § 200.214 Suspension and debarment indicates non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate procurement process. Questioned costs: N/A Context: 5 of 5 vendors selected for procurement testing, did not have documentation showing that the cost had been procured in accordance with the Uniform Guidance. Additionally, 2 of 2 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate procurement, suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: No Recommendation: We recommend the Organization revised its internal controls related to procurement, suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization is in the process of developing a procurement policy and suspension and debarment policies that aligns with Uniform Guidance.
2023-004 – Procurement, Suspension and Debarment Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; Illinois Criminal Justice Information Authority Pass-Through Number(s): 20220246 - 2023; 20220245 - 2023; 822007 - 2023 Award Period: 3/1/22-12/31/23; 3/1/22-12/31/23; 3/1/22-12/31/24; 4/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: CFR § 200.320 indicates the various methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and § 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. § 200.214 Suspension and debarment indicates non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate procurement process. Questioned costs: N/A Context: 5 of 5 vendors selected for procurement testing, did not have documentation showing that the cost had been procured in accordance with the Uniform Guidance. Additionally, 2 of 2 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate procurement, suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: No Recommendation: We recommend the Organization revised its internal controls related to procurement, suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization is in the process of developing a procurement policy and suspension and debarment policies that aligns with Uniform Guidance.
2023-004 – Procurement, Suspension and Debarment Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; Illinois Criminal Justice Information Authority Pass-Through Number(s): 20220246 - 2023; 20220245 - 2023; 822007 - 2023 Award Period: 3/1/22-12/31/23; 3/1/22-12/31/23; 3/1/22-12/31/24; 4/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: CFR § 200.320 indicates the various methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and § 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. § 200.214 Suspension and debarment indicates non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate procurement process. Questioned costs: N/A Context: 5 of 5 vendors selected for procurement testing, did not have documentation showing that the cost had been procured in accordance with the Uniform Guidance. Additionally, 2 of 2 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate procurement, suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: No Recommendation: We recommend the Organization revised its internal controls related to procurement, suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization is in the process of developing a procurement policy and suspension and debarment policies that aligns with Uniform Guidance.
III ‐ Findings and Questioned Costs – Major Federal Award Program Finding No. 2023‐002 National Science Foundation ‐ Research and Development Cluster Federal Assistance Listing Number #47.070 ‐ Compliance Requirement Code: I‐Procurement and Suspension and Debarment Criteria In accordance with §200.318(a), General Procurement Standards, a non‐federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non‐federal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, non‐federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition For the procurement samples tested, Management did not provide adequate supporting documentation for the procurement including ensuring proper suspension and debarment checks were performed. Cause The Organization did not have adequate policies, procedures, and controls in place to ensure compliance with the general procurement standards and suspension and debarment requirements. Effect or Potential Effect Failure to perform procurement procedures in accordance with a written policy that complies with the Uniform Guidance could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Not applicable. Context For three procurement samples out of a total of three tested, management did not provide adequate supporting documentation for the procurement transaction. Repeat Finding: No Recommendation We recommend that the Organization establish written procurement policies and procedures to ensure that Organization is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Views of Responsible Officials Our understanding of the finding is that it pertains to the following sections of 2 CFR 180: § 180.220 Are any procurement contracts included as covered transactions? (a) Covered transactions under this part— (1) Do not include any procurement contracts awarded directly by a Federal agency; but (2) Do include some procurement contracts awarded by non Federal participants in nonprocurement covered transactions. (b) Specifically, a contract for goods or services is a covered transaction if any of the following applies: (1) The contract is awarded by a participant in a nonprocurement transaction that is covered under §180.210, and the amount of the contract is expected to equal or exceed $25,000. (2) The contract requires the consent of an official of a Federal agency. In that case, the contract, regardless of the amount, always is a covered transaction, and it does not matter who awarded it. For example, it could be a subcontract awarded by a contractor at a tier below a nonprocurement transaction, as shown in the appendix to this part. § 180.300 What must I do before I enter into a covered transaction with another person at the next lower tier? When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. To support compliance with these requirements, MGHPCC controls for federal programs in place in FY23 included the following provision: Criteria for approval of Purchase Orders above $25,000 include a check to ensure that the vendors are not suspended disbarred, or otherwise excluded from participating in a covered transaction as defined in 2CFR 180.220 and 2CFR 180.300. To address the finding noted above, we have added the following documentation requirement: Policy has been updated to require that the check be documented by capturing a copy of the entity information database entry at www.sam.gov as part of the Purchase Order approval process for vendorswho exceed the threshold defined in 2CFR 180.220 and 2CFR 180.300. The entity information database report includes a time stamp, which serves as an indication of when the database entry was checked.
2023-006 - Internal Control Over Compliance and Compliance – Procurement, Suspension and Debarment Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Criteria - In accordance with 2 CFR §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition – During our testing of the procurement, suspension and debarment compliance requirements, we identified one procurement sample out of a total of two procurement samples tested wherein management was unable to provide evidence that the suspension and debarment check was performed prior to entering into contract with the vendor. Management has subsequently determined that the vendor was not suspended or debarred. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center’s personnel did not adhere to NGA Center’s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a covered transaction. Effect – Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering a contract with an entity that is barred from performing work for the Federal government. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2023-001 Improve Controls and Documentation Over Procurement Federal Agency: U.S. Department of the Treasury Cluster/Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Fund AL Numbers: 21.027 Award Year: 2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding Compliance Internal Control over Compliance - Significant Deficiency Criteria or Specific Requirement Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must 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 requirements identified in 2 CFR Part 200. Local municipalities are also required to use the same state procurement policies and procedures for federal funds as for non-federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context There was no evidence to support that one disbursement properly followed the procurement process before payments for services were made to the vendor. Cause Weaknesses in the design and operation of controls. 2023-001 Improve Controls and Documentation Over Procurement (Continued) Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is a risk that procurements may be awarded to vendors in a manner that is not consistent with federal procurement requirements. Known questioned costs are reported equal to $82,800, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Fund $82,800 Recommendation The Town should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal and state requirements. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Special Education Cluster (IDEA) – ALN 84.027X & 84.173X Criteria: Per 2 CFR section 200.318, a grantee meet general procurement standards which include maintaining records to document the history of procurements. Furthermore, the pass-through agency’s requirements for sole source procurements include a requirement that the procurement officer must determine in writing that only one “practicable source” exists and record the reasoning. Condition: Two vendors were awarded a contract through a sole source procurement without a written determination that only one practicable source existed and the reasoning for such a determination. Cause: The School was unaware of the documentation requirements. Effect: The Town is not in compliance with Federal and State procurement requirements. Questioned Costs: $28,025 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to include in its procurement files a written determination for all sole source procurements. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Special Education Cluster (IDEA) – ALN 84.027X & 84.173X Criteria: Per 2 CFR section 200.318, a grantee meet general procurement standards which include maintaining records to document the history of procurements. Furthermore, the pass-through agency’s requirements for sole source procurements include a requirement that the procurement officer must determine in writing that only one “practicable source” exists and record the reasoning. Condition: Two vendors were awarded a contract through a sole source procurement without a written determination that only one practicable source existed and the reasoning for such a determination. Cause: The School was unaware of the documentation requirements. Effect: The Town is not in compliance with Federal and State procurement requirements. Questioned Costs: $28,025 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to include in its procurement files a written determination for all sole source procurements. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Special Education Cluster (IDEA) – ALN 84.027X & 84.173X Criteria: Per 2 CFR section 200.318, a grantee meet general procurement standards which include maintaining records to document the history of procurements. Furthermore, the pass-through agency’s requirements for sole source procurements include a requirement that the procurement officer must determine in writing that only one “practicable source” exists and record the reasoning. Condition: Two vendors were awarded a contract through a sole source procurement without a written determination that only one practicable source existed and the reasoning for such a determination. Cause: The School was unaware of the documentation requirements. Effect: The Town is not in compliance with Federal and State procurement requirements. Questioned Costs: $28,025 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to include in its procurement files a written determination for all sole source procurements. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Special Education Cluster (IDEA) – ALN 84.027X & 84.173X Criteria: Per 2 CFR section 200.318, a grantee meet general procurement standards which include maintaining records to document the history of procurements. Furthermore, the pass-through agency’s requirements for sole source procurements include a requirement that the procurement officer must determine in writing that only one “practicable source” exists and record the reasoning. Condition: Two vendors were awarded a contract through a sole source procurement without a written determination that only one practicable source existed and the reasoning for such a determination. Cause: The School was unaware of the documentation requirements. Effect: The Town is not in compliance with Federal and State procurement requirements. Questioned Costs: $28,025 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to include in its procurement files a written determination for all sole source procurements. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Special Education Cluster (IDEA) – ALN 84.027X & 84.173X Criteria: Per 2 CFR section 200.318, a grantee meet general procurement standards which include maintaining records to document the history of procurements. Furthermore, the pass-through agency’s requirements for sole source procurements include a requirement that the procurement officer must determine in writing that only one “practicable source” exists and record the reasoning. Condition: Two vendors were awarded a contract through a sole source procurement without a written determination that only one practicable source existed and the reasoning for such a determination. Cause: The School was unaware of the documentation requirements. Effect: The Town is not in compliance with Federal and State procurement requirements. Questioned Costs: $28,025 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to include in its procurement files a written determination for all sole source procurements. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Special Education Cluster (IDEA) – ALN 84.027X & 84.173X Criteria: Per 2 CFR section 200.318, a grantee meet general procurement standards which include maintaining records to document the history of procurements. Furthermore, the pass-through agency’s requirements for sole source procurements include a requirement that the procurement officer must determine in writing that only one “practicable source” exists and record the reasoning. Condition: Two vendors were awarded a contract through a sole source procurement without a written determination that only one practicable source existed and the reasoning for such a determination. Cause: The School was unaware of the documentation requirements. Effect: The Town is not in compliance with Federal and State procurement requirements. Questioned Costs: $28,025 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to include in its procurement files a written determination for all sole source procurements. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Special Education Cluster (IDEA) – ALN 84.027X & 84.173X Criteria: Per 2 CFR section 200.318, a grantee meet general procurement standards which include maintaining records to document the history of procurements. Furthermore, the pass-through agency’s requirements for sole source procurements include a requirement that the procurement officer must determine in writing that only one “practicable source” exists and record the reasoning. Condition: Two vendors were awarded a contract through a sole source procurement without a written determination that only one practicable source existed and the reasoning for such a determination. Cause: The School was unaware of the documentation requirements. Effect: The Town is not in compliance with Federal and State procurement requirements. Questioned Costs: $28,025 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to include in its procurement files a written determination for all sole source procurements. Views of Responsible Official: Management agrees with the finding.
Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number: SLFRP0128 Grant Year: 2021 Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: June 7, 2021, through December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The Cities procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Policies regarding verification of compliance with suspension and debarment requirements were not found. Questioned Costs: None Context: Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria the population of expenditures requiring testing were immaterial or otherwise excluded from testing requirements. Effect: With the absence of a compliant policy, the City could process transactions that do not follow federal Uniform Guidance procurement standards. Repeat Finding: Yes, 2022-004 Cause: The City was in the process of updating their policy to be in line with the Uniform Guidance procurement standards, but was unable to finalize the policy prior to incurring allowable costs. Recommendation: We recommend the City comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number: SLFRP0128 Grant Year: 2021 Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: June 7, 2021, through December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The Cities procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Policies regarding verification of compliance with suspension and debarment requirements were not found. Questioned Costs: None Context: Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria the population of expenditures requiring testing were immaterial or otherwise excluded from testing requirements. Effect: With the absence of a compliant policy, the City could process transactions that do not follow federal Uniform Guidance procurement standards. Repeat Finding: Yes, 2022-004 Cause: The City was in the process of updating their policy to be in line with the Uniform Guidance procurement standards, but was unable to finalize the policy prior to incurring allowable costs. Recommendation: We recommend the City comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number: SLFRP0128 Grant Year: 2021 Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: June 7, 2021, through December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The Cities procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Policies regarding verification of compliance with suspension and debarment requirements were not found. Questioned Costs: None Context: Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria the population of expenditures requiring testing were immaterial or otherwise excluded from testing requirements. Effect: With the absence of a compliant policy, the City could process transactions that do not follow federal Uniform Guidance procurement standards. Repeat Finding: Yes, 2022-004 Cause: The City was in the process of updating their policy to be in line with the Uniform Guidance procurement standards, but was unable to finalize the policy prior to incurring allowable costs. Recommendation: We recommend the City comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number: SLFRP0128 Grant Year: 2021 Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: June 7, 2021, through December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The Cities procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Policies regarding verification of compliance with suspension and debarment requirements were not found. Questioned Costs: None Context: Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria the population of expenditures requiring testing were immaterial or otherwise excluded from testing requirements. Effect: With the absence of a compliant policy, the City could process transactions that do not follow federal Uniform Guidance procurement standards. Repeat Finding: Yes, 2022-004 Cause: The City was in the process of updating their policy to be in line with the Uniform Guidance procurement standards, but was unable to finalize the policy prior to incurring allowable costs. Recommendation: We recommend the City comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
Finding Type. Significant Deficiency in Internal Control over Compliance and Immaterial Noncompliance (Procurement and Suspension and Debarment) Program. Drinking Water State Revolving Fund Cluster (CFDA# 66.468); U.S. Department of Environmental Protection Agency; Passed through the Oregon Infrastructure Finance Authority of the Oregon Business Development Department; Project number S22008. Criteria. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must 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 requirements identified in 2 CFR Part 200. Condition. The District did not have documented procurement standards to comply with 2 CFR sections 200.318 through 200.326. Cause. The District was not aware that written policies were required for these areas in accordance with 2 CFR Part 200. Effect. As a result of this condition, the District did not fully comply with 2 CFR Part 200 applicable to the above noted grant. Questioned Costs. No costs have been questioned as a result of this finding. Recommendation. We recommend that the District develop a policy as soon as practical, but no later than the end of fiscal year 2024, to comply with 2 CFR sections 200.318 through 200.326. View of Responsible Officials. We agree with the recommendation and will develop procedures to comply with the Uniform Guidance applicable to grants.
CONDITION: The Moniteau School District contracted with a third-party vendor (Smart Solutions Technologies) for technology equipment (Smart Boards and Mobile Carts) for the District which exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. This is a repeat finding (2022-001) from prior fiscal year. CRITERIA: 24 Pa. Statutes 751 of the Public School Code and Section 2 CFR 200.318(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a school district whereby the cost exceeds certain dollar thresholds as adjusted annually for an inflation index. As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. CAUSE: School District personnel directly responsible for the oversight and execution of this contract, unintentionally assumed that this particular third-party contract did not require the specific bidding requirements as outlined in both 24 Pa. Statutes 751 of the Public School Code and Section 2 CFR 200.318(i) of the Uniform Guidance. EFFECT: The Moniteau School District did not comply with the requirements of 2 CFR 200.318(i) of the Uniform Guidance with regard to maintaining records sufficient to detail the history of procurement for the technology equipment. QUESTIONED COST: $184,219 RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, so as to comply with all applicable sections of the Uniform Guidance, in specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I am recommending that management contact the PA Department of Education, and explain the circumstances and oversight, and seek direction as to the allowability of this program cost in writing for their permanent files. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Associates in Counseling’. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance, and District Procurement Policy #626, regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: $82,119 CAUSE: The District utilized this vendor as they felt these professional services best fit the needs of the District. However, the additional procedures addressed in its Procurement Policy for Federal Programs (#626) which addresses the issue of noncompetitive procurement as outlined in Section 2 CFR 200.320(c’), were inadvertently not performed. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Associates in Counseling’. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance, and District Procurement Policy #626, regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: $82,119 CAUSE: The District utilized this vendor as they felt these professional services best fit the needs of the District. However, the additional procedures addressed in its Procurement Policy for Federal Programs (#626) which addresses the issue of noncompetitive procurement as outlined in Section 2 CFR 200.320(c’), were inadvertently not performed. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Associates in Counseling’. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance, and District Procurement Policy #626, regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: $82,119 CAUSE: The District utilized this vendor as they felt these professional services best fit the needs of the District. However, the additional procedures addressed in its Procurement Policy for Federal Programs (#626) which addresses the issue of noncompetitive procurement as outlined in Section 2 CFR 200.320(c’), were inadvertently not performed. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Associates in Counseling’. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance, and District Procurement Policy #626, regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: $82,119 CAUSE: The District utilized this vendor as they felt these professional services best fit the needs of the District. However, the additional procedures addressed in its Procurement Policy for Federal Programs (#626) which addresses the issue of noncompetitive procurement as outlined in Section 2 CFR 200.320(c’), were inadvertently not performed. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
MATERIAL WEAKNESSES 2023-001 - Procurement Policy Federal Program Information: Department of Environmental Protection: 66.468 / 66.483 Drinking Water State Revolving Fund Cluster Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.318 through 200.327. Condition: During audit procedures, it was identified that the Royalton Fire District did not have a procurement policy consistent with federal compliance standards. Cause: The District did not adopt a procurement policy consistent with federal regulations. Effect: By not having a compliant federal procurement policy, the District is at an increased risk for making unallowable purchases. Identification of Questioned Costs: None identified. Context: A review was conducted of the Distict’s procurement policy and the policy was not in compliance with Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the District adopt a federal procurement policy that is consistent with Uniform Guidance. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding, and the unabridged version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the District.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCES OF NONCOMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – (FEDERAL ALN 10.553, 10.555, AND 10.559) 2023-004 Internal Control Over Compliance and Reportable Instances of Noncompliance With Federal Procurement, and Suspension and Debarment Requirements Criteria – 2 CFR § 180 and 2 CFR § 200.318-327 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, and suspension and debarment requirements applicable to the child nutrition cluster federal programs. Condition – During our audit, we noted the Academy did not have sufficient controls in place resulting in material noncompliance within its child nutrition cluster 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 Academy did not follow Uniform Guidance requirements related to methods of procurement applicable to federal program expenditures. The Academy also did not have proper documentation of suspension and debarment requirements maintained for one of one vendor tested to ensure compliance with this requirement in the current year. These were not statistically valid samples. Repeat Finding – This is a current year finding. Cause – This was an oversight by academy personnel. Effect – Noncompliance with procurement, and suspension and debarment requirements could result in the Academy 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 Academy review its internal control procedures relating to procurement, and suspension and debarment for the child nutrition cluster federal program. Internal controls over compliance for this area should include documentation of compliance with Uniform Guidance requirements related to methods of procurement. These controls should also include steps to ensure any vendor with which the Academy 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 Academy agrees with the finding. The Academy will review procedures relating to procurement, and suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The Academy has separately issued a Corrective Action Plan related to this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCES OF NONCOMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – (FEDERAL ALN 10.553, 10.555, AND 10.559) 2023-004 Internal Control Over Compliance and Reportable Instances of Noncompliance With Federal Procurement, and Suspension and Debarment Requirements Criteria – 2 CFR § 180 and 2 CFR § 200.318-327 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, and suspension and debarment requirements applicable to the child nutrition cluster federal programs. Condition – During our audit, we noted the Academy did not have sufficient controls in place resulting in material noncompliance within its child nutrition cluster 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 Academy did not follow Uniform Guidance requirements related to methods of procurement applicable to federal program expenditures. The Academy also did not have proper documentation of suspension and debarment requirements maintained for one of one vendor tested to ensure compliance with this requirement in the current year. These were not statistically valid samples. Repeat Finding – This is a current year finding. Cause – This was an oversight by academy personnel. Effect – Noncompliance with procurement, and suspension and debarment requirements could result in the Academy 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 Academy review its internal control procedures relating to procurement, and suspension and debarment for the child nutrition cluster federal program. Internal controls over compliance for this area should include documentation of compliance with Uniform Guidance requirements related to methods of procurement. These controls should also include steps to ensure any vendor with which the Academy 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 Academy agrees with the finding. The Academy will review procedures relating to procurement, and suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The Academy has separately issued a Corrective Action Plan related to this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCES OF NONCOMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – (FEDERAL ALN 10.553, 10.555, AND 10.559) 2023-004 Internal Control Over Compliance and Reportable Instances of Noncompliance With Federal Procurement, and Suspension and Debarment Requirements Criteria – 2 CFR § 180 and 2 CFR § 200.318-327 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, and suspension and debarment requirements applicable to the child nutrition cluster federal programs. Condition – During our audit, we noted the Academy did not have sufficient controls in place resulting in material noncompliance within its child nutrition cluster 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 Academy did not follow Uniform Guidance requirements related to methods of procurement applicable to federal program expenditures. The Academy also did not have proper documentation of suspension and debarment requirements maintained for one of one vendor tested to ensure compliance with this requirement in the current year. These were not statistically valid samples. Repeat Finding – This is a current year finding. Cause – This was an oversight by academy personnel. Effect – Noncompliance with procurement, and suspension and debarment requirements could result in the Academy 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 Academy review its internal control procedures relating to procurement, and suspension and debarment for the child nutrition cluster federal program. Internal controls over compliance for this area should include documentation of compliance with Uniform Guidance requirements related to methods of procurement. These controls should also include steps to ensure any vendor with which the Academy 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 Academy agrees with the finding. The Academy will review procedures relating to procurement, and suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The Academy has separately issued a Corrective Action Plan related to this finding.
CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from three (3) vendors - CJAWS, Inc., Edmentum, Inc., and SapphireK12, Inc. This is a repeat finding (2022-007) from the previous fiscal year for CJAWS, Inc. and Edmentum, Inc. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2 CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: CJAWS, Inc. - $33,498, Edmentum, Inc. - $19,190, SapphireK12, Inc. $26,651 CAUSE: From a review of the School District’s policies as published on the District’s website, the District has not updated their policies to include those related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). RECOMMENDATION: I recommend that the School District update their policies to include those most recent related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). In addition, I would recommend that District personnel responsible for expenditures related to federal funding receive updated training related to ‘procurement’ policies and procedures as they relate to federal funding. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from three (3) vendors - CJAWS, Inc., Edmentum, Inc., and SapphireK12, Inc. This is a repeat finding (2022-007) from the previous fiscal year for CJAWS, Inc. and Edmentum, Inc. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2 CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: CJAWS, Inc. - $33,498, Edmentum, Inc. - $19,190, SapphireK12, Inc. $26,651 CAUSE: From a review of the School District’s policies as published on the District’s website, the District has not updated their policies to include those related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). RECOMMENDATION: I recommend that the School District update their policies to include those most recent related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). In addition, I would recommend that District personnel responsible for expenditures related to federal funding receive updated training related to ‘procurement’ policies and procedures as they relate to federal funding. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from three (3) vendors - CJAWS, Inc., Edmentum, Inc., and SapphireK12, Inc. This is a repeat finding (2022-007) from the previous fiscal year for CJAWS, Inc. and Edmentum, Inc. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2 CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: CJAWS, Inc. - $33,498, Edmentum, Inc. - $19,190, SapphireK12, Inc. $26,651 CAUSE: From a review of the School District’s policies as published on the District’s website, the District has not updated their policies to include those related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). RECOMMENDATION: I recommend that the School District update their policies to include those most recent related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). In addition, I would recommend that District personnel responsible for expenditures related to federal funding receive updated training related to ‘procurement’ policies and procedures as they relate to federal funding. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from three (3) vendors - CJAWS, Inc., Edmentum, Inc., and SapphireK12, Inc. This is a repeat finding (2022-007) from the previous fiscal year for CJAWS, Inc. and Edmentum, Inc. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2 CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: CJAWS, Inc. - $33,498, Edmentum, Inc. - $19,190, SapphireK12, Inc. $26,651 CAUSE: From a review of the School District’s policies as published on the District’s website, the District has not updated their policies to include those related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). RECOMMENDATION: I recommend that the School District update their policies to include those most recent related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). In addition, I would recommend that District personnel responsible for expenditures related to federal funding receive updated training related to ‘procurement’ policies and procedures as they relate to federal funding. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from three (3) vendors - CJAWS, Inc., Edmentum, Inc., and SapphireK12, Inc. This is a repeat finding (2022-007) from the previous fiscal year for CJAWS, Inc. and Edmentum, Inc. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2 CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: CJAWS, Inc. - $33,498, Edmentum, Inc. - $19,190, SapphireK12, Inc. $26,651 CAUSE: From a review of the School District’s policies as published on the District’s website, the District has not updated their policies to include those related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). RECOMMENDATION: I recommend that the School District update their policies to include those most recent related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). In addition, I would recommend that District personnel responsible for expenditures related to federal funding receive updated training related to ‘procurement’ policies and procedures as they relate to federal funding. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
Inadequate Records Retention (Procurement) Criteria: Per Federal regulations for general procurement standards (2 CFR § 200.318 (i)), non-Federal entity must maintain records sufficient to detail the history of the procurement process. These records will include but are not limited to, the following: Rationale for the method of procurement, selection or rejection, and the basis for the contract price. Condition: In our procurement testing for CSLFRF funding, the City was unable to provide evidence that demonstrates public notice was published according to (2 CFR § 200.320(b)) for 1 of the 5 projects selected. Questioned Costs: $0 Cause and Effect: Due to the City not having a centralized repository for procurement records, sufficient evidence was unable to verify that procurements provide full and open competition to potential bidders, as there was a lack of documentation related to the public notice for open bidding to occur. Recommendation: We recommend the City updates their procurement policies and procedures by centrally tracking procurement documents for up to five years. Centrally tracking documentation will help the City mitigate potential contractual and administrative issues related to procurement. Management Response: The Finance Director is initiating conversations with department heads regarding updating procurement policies and procedures. We are taking steps to ensure all procurement documents are stored centrally in order for these items to be readily available moving forward.
Section III - Federal Awards Findings and Questioned Costs MATERIAL WEAKNESSES 2023-001 - Procurement Policy Federal Program Information: Department of Environmental Protection: 66.458/66.482 Clean Water State Revolving Funds Cluster 21.027 Coronavirus State Local Fiscal Recovery Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.318 through 200.327. Condition: During audit procedures, it was identified that the Town of Van Buren did not have a procurement policy consistent with federal compliance standards. Cause: The District did not adopt a procurement policy consistent with federal regulations. Effect: By not having a compliant federal procurement policy, the Town is at an increased risk for making unallowable purchases. Identification of Questioned Costs: None identified. Context: A review was conducted of the Town’s procurement policy and the policy was not in compliance with Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the Town adopt a federal procurement policy that is consistent with Uniform Guidance. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding, and the unabridged version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the District.