Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): SY 2020/2021, SY 2021/2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases ? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 2 CFR 180.300 states in part: "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 Exclusion; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 for when informal procedures can be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for three of the five vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Suspension and Debarment Non-federal entities and contractors are subject to non-procurement debarment and suspension regulations. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or are ineligible for participation in Federal assistance programs or activities. This is done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. During fiscal years 2020-2021 and 2021-2022, the School Corporation entered into a covered transaction with Stanz Food Service, Inc.. Procedures were not performed to ensure that the vendor was not suspended, debarred, or otherwise excluded from or eligible for participation in Federal assistance programs or activities. The lack of controls and noncompliance were systemic issues throughout the audit period. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that 3 quotes are obtained as required for small purchase method procurements and to ensure the vendors are not debarred or suspended. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): SY 2020/2021, SY 2021/2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases ? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 2 CFR 180.300 states in part: "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 Exclusion; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 for when informal procedures can be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for three of the five vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Suspension and Debarment Non-federal entities and contractors are subject to non-procurement debarment and suspension regulations. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or are ineligible for participation in Federal assistance programs or activities. This is done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. During fiscal years 2020-2021 and 2021-2022, the School Corporation entered into a covered transaction with Stanz Food Service, Inc.. Procedures were not performed to ensure that the vendor was not suspended, debarred, or otherwise excluded from or eligible for participation in Federal assistance programs or activities. The lack of controls and noncompliance were systemic issues throughout the audit period. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that 3 quotes are obtained as required for small purchase method procurements and to ensure the vendors are not debarred or suspended. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): SY 2020/2021, SY 2021/2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases ? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 2 CFR 180.300 states in part: "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 Exclusion; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 for when informal procedures can be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for three of the five vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Suspension and Debarment Non-federal entities and contractors are subject to non-procurement debarment and suspension regulations. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or are ineligible for participation in Federal assistance programs or activities. This is done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. During fiscal years 2020-2021 and 2021-2022, the School Corporation entered into a covered transaction with Stanz Food Service, Inc.. Procedures were not performed to ensure that the vendor was not suspended, debarred, or otherwise excluded from or eligible for participation in Federal assistance programs or activities. The lack of controls and noncompliance were systemic issues throughout the audit period. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that 3 quotes are obtained as required for small purchase method procurements and to ensure the vendors are not debarred or suspended. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Assistance Listing Numbers: 10.533, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 83-8010 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed nor implemented an effective system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not follow procurement requirements for purchases of milk and dairy which fell under small purchase procedures. The School Corporation did not obtain price or rate quotes from an adequate number of qualified sources for the one vendor used for the purchase of milk and dairy during FY 2021. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Assistance Listing Numbers: 10.533, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 83-8010 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed nor implemented an effective system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not follow procurement requirements for purchases of milk and dairy which fell under small purchase procedures. The School Corporation did not obtain price or rate quotes from an adequate number of qualified sources for the one vendor used for the purchase of milk and dairy during FY 2021. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Assistance Listing Numbers: 10.533, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 83-8010 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed nor implemented an effective system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not follow procurement requirements for purchases of milk and dairy which fell under small purchase procedures. The School Corporation did not obtain price or rate quotes from an adequate number of qualified sources for the one vendor used for the purchase of milk and dairy during FY 2021. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Assistance Listing Number, Federal Agency, and Program Name - 84.425F, 84.425M, 84.425N; U.S. Department of Education; HEERF Institutional Portion, HEERF Strengthening Institutions Program (SIP), HEERF Fund for Improvement of Postsecondary Education (FIPSE) Formula Grant. Federal Award Identification Number and Year - P425F204736, P425M201046-20A , P425N200748 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.318 - The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition - The Corporation's procurement procedures does not fully conform to the procurements standards identified in ?? 200.317 through 200.327. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During testing we did not identify any instances of noncompliance related to procurement. However, during the review of the policies we discovered the following provisions of the standards were not in conformity with Uniform Guidance: * ? 200.318 - general procurement standard: the policy excluded a written standard of conduct covering conflicts of interest, including organizational conflicts of interest * ? 200.320 - methods of procurement: the policy does not appear to conform to the standards specific to non-construction purchases in excess of the small acquisition threshold * ?? 200.321 - 300.326 are not addressed in the policies Cause and Effect - Controls in place did not ensure the procurement policies and procedures conformed to the procurement standards identified in ?? 200.317 through 200.327. The lack of controls could result in acquisition of property or services that does not provide full and open competition and could result in disallowed costs. Recommendation - The Corporation should review the procurement standards identified in ?? 200.317 through 200.327 to identify policy deficiencies and work to establish policy that will confirm to the standards. Views of Responsible Officials and Planned Corrective Actions - Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.
Assistance Listing Number, Federal Agency, and Program Name - 84.425F, 84.425M, 84.425N; U.S. Department of Education; HEERF Institutional Portion, HEERF Strengthening Institutions Program (SIP), HEERF Fund for Improvement of Postsecondary Education (FIPSE) Formula Grant. Federal Award Identification Number and Year - P425F204736, P425M201046-20A , P425N200748 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.318 - The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition - The Corporation's procurement procedures does not fully conform to the procurements standards identified in ?? 200.317 through 200.327. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During testing we did not identify any instances of noncompliance related to procurement. However, during the review of the policies we discovered the following provisions of the standards were not in conformity with Uniform Guidance: * ? 200.318 - general procurement standard: the policy excluded a written standard of conduct covering conflicts of interest, including organizational conflicts of interest * ? 200.320 - methods of procurement: the policy does not appear to conform to the standards specific to non-construction purchases in excess of the small acquisition threshold * ?? 200.321 - 300.326 are not addressed in the policies Cause and Effect - Controls in place did not ensure the procurement policies and procedures conformed to the procurement standards identified in ?? 200.317 through 200.327. The lack of controls could result in acquisition of property or services that does not provide full and open competition and could result in disallowed costs. Recommendation - The Corporation should review the procurement standards identified in ?? 200.317 through 200.327 to identify policy deficiencies and work to establish policy that will confirm to the standards. Views of Responsible Officials and Planned Corrective Actions - Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.
Assistance Listing Number, Federal Agency, and Program Name - 84.425F, 84.425M, 84.425N; U.S. Department of Education; HEERF Institutional Portion, HEERF Strengthening Institutions Program (SIP), HEERF Fund for Improvement of Postsecondary Education (FIPSE) Formula Grant. Federal Award Identification Number and Year - P425F204736, P425M201046-20A , P425N200748 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.318 - The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition - The Corporation's procurement procedures does not fully conform to the procurements standards identified in ?? 200.317 through 200.327. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During testing we did not identify any instances of noncompliance related to procurement. However, during the review of the policies we discovered the following provisions of the standards were not in conformity with Uniform Guidance: * ? 200.318 - general procurement standard: the policy excluded a written standard of conduct covering conflicts of interest, including organizational conflicts of interest * ? 200.320 - methods of procurement: the policy does not appear to conform to the standards specific to non-construction purchases in excess of the small acquisition threshold * ?? 200.321 - 300.326 are not addressed in the policies Cause and Effect - Controls in place did not ensure the procurement policies and procedures conformed to the procurement standards identified in ?? 200.317 through 200.327. The lack of controls could result in acquisition of property or services that does not provide full and open competition and could result in disallowed costs. Recommendation - The Corporation should review the procurement standards identified in ?? 200.317 through 200.327 to identify policy deficiencies and work to establish policy that will confirm to the standards. Views of Responsible Officials and Planned Corrective Actions - Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
Information on the Federal Program U.S. Department of Education ? Passed-through New Jersey Department of Education: Education Stabilization Fund (ESF): ESSER ? CARES Emergency Relief Grant Assistance Listing No. 84.425 3/13/2020 ? 9/30/2022 ESSER II Assistance Listing No. 84.425 3/13/2020 ? 9/30/2023 ESSER ? American Rescue Plan Assistance Listing No. 84.425 3/13/2020 ? 9/30/2024 Homeless II ? American Rescue Plan Assistance Listing No. 84.425 4/23/2021 ? 9/30/2023 Criteria or Specific Requirement Per 2 CFR ? 200.320 under Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards dictates when the value of procurement for property or services exceed the simplified acquisition threshold or a lower threshold established by a non-Federal entity (State of New Jersey), formal procurement methods are required. Condition The School District did not provide evidence that it was in compliance with formal procurement methods. Questioned Costs Unknown. Context Two (2) purchases made by the School District in excess of the procurement threshold established by a non-Federal entity (State of New Jersey) did not have supporting documentation available to verify compliance with formal procurement methods. Effect or Potential Effect The School District was not in compliance with 2 CFR ? 200.320 under Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Cause Unknown. Identification as a Repeat Finding See Finding 2021-004. Recommendation That the School District retain evidence that it complied with formal procurement methods as noted in 2 CFR ? 200.320 under Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. View of Responsible Officials and Planned Corrective Action The responsible officials agree with the finding and will address the matter as part of their corrective action plan.
Finding Number: 2022-002 Assistance Listing Number and Title: AL #84.027, #84.173 Special Education Cluster Federal Award Identification Number/ Year: 2022/2023 Federal Agency: U.S. Department of Education Compliance Requirement: Procurement and Suspension and Debarment Pass-Through Entity: Ohio Department of Education Repeat Finding from Prior Audit? No Ohio Rev. Code ?? 3313.843 and 3313.845 allow traditional schools to contract with Educational Service Centers (ESCs) to provide services as outlined in the agreement between the two parties. Ohio Rev. Code ?3313.843(C) requires these agreements to be filed with the Ohio Department of Education by the first day of July of the school year for which the agreement is in effect. Effective on December 26, 2014, 2 CFR ? 200.320 outlined the methods of procurement to be followed by state subrecipient non-Federal entities when expending certain types of Federal funds, including those received through Grant Agreements. However, 2 CFR ? 200.110(a), created a ?grace period? for compliance with 2 CFR ?200.320, by permitting non-Federal entities to comply with previously issued Office of Management and Budget procurement guidance for all fiscal years beginning prior to December 26, 2017. In January 2020, the Ohio Department of Education (ODE) published a form that allows schools to request ODE authorize a noncompetitive proposal for their ESC Services. This form is available on ODE?s website. During the fiscal year, the School District contracted with Allen County Educational Service Center (ESC) to provide purchased services. These services included expenditures of $46,283, which were paid for out of the Special Education Cluster Grants and subject to the Federal procurement laws. The School District did not complete the form that allows schools to request ODE authorize a noncompetitive proposal for their ESC Services that is available on the ODE website. Under 2 CFR ?200.320 the School District should have competitively bid the services needed or obtained price quotes from qualified sources as further defined in the School District?s procurement policy. The School District should develop a control(s) and/or procedure(s) to verify that established procurement procedures are followed when entering into contracts using Federal monies. The ODE form that allows schools to request ODE authorize a noncompetitive proposal for their ESC Services should be utilized for any ESC contract in the future. Failure to follow proper procurement procedures could result in contracts awarded to entities which do not meet all the needs of the School District or have a cost significantly higher than their competitors, as well as a loss in future federal funding and possible questioned costs in future audits.
Finding Number: 2022-002 Assistance Listing Number and Title: AL #84.027, #84.173 Special Education Cluster Federal Award Identification Number/ Year: 2022/2023 Federal Agency: U.S. Department of Education Compliance Requirement: Procurement and Suspension and Debarment Pass-Through Entity: Ohio Department of Education Repeat Finding from Prior Audit? No Ohio Rev. Code ?? 3313.843 and 3313.845 allow traditional schools to contract with Educational Service Centers (ESCs) to provide services as outlined in the agreement between the two parties. Ohio Rev. Code ?3313.843(C) requires these agreements to be filed with the Ohio Department of Education by the first day of July of the school year for which the agreement is in effect. Effective on December 26, 2014, 2 CFR ? 200.320 outlined the methods of procurement to be followed by state subrecipient non-Federal entities when expending certain types of Federal funds, including those received through Grant Agreements. However, 2 CFR ? 200.110(a), created a ?grace period? for compliance with 2 CFR ?200.320, by permitting non-Federal entities to comply with previously issued Office of Management and Budget procurement guidance for all fiscal years beginning prior to December 26, 2017. In January 2020, the Ohio Department of Education (ODE) published a form that allows schools to request ODE authorize a noncompetitive proposal for their ESC Services. This form is available on ODE?s website. During the fiscal year, the School District contracted with Allen County Educational Service Center (ESC) to provide purchased services. These services included expenditures of $46,283, which were paid for out of the Special Education Cluster Grants and subject to the Federal procurement laws. The School District did not complete the form that allows schools to request ODE authorize a noncompetitive proposal for their ESC Services that is available on the ODE website. Under 2 CFR ?200.320 the School District should have competitively bid the services needed or obtained price quotes from qualified sources as further defined in the School District?s procurement policy. The School District should develop a control(s) and/or procedure(s) to verify that established procurement procedures are followed when entering into contracts using Federal monies. The ODE form that allows schools to request ODE authorize a noncompetitive proposal for their ESC Services should be utilized for any ESC contract in the future. Failure to follow proper procurement procedures could result in contracts awarded to entities which do not meet all the needs of the School District or have a cost significantly higher than their competitors, as well as a loss in future federal funding and possible questioned costs in future audits.
Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases, (ELC) Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance, Material Weakness in Internal Control over Compliance Criteria: Procurement: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. 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. A non-federal entity must: ? Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. ? Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. ? Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements [Davis-Bacon Act]). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). ? Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). ? Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, ?Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.? Suspension and Debarment: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/Home, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition Found: As a result of our audit procedures, we noted the following: Procurement: ? 4 out of 8 transactions tested did not have documentation that full and open competition, price analysis, or rationale to limit competition in those cases where competition was limited. ? 2 out of 8 transactions tested did not have documentation of the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract price in accordance with the Uniform Guidance, section 318(i) and 48 CFR part 44 and section 52.244-2. ? 8 out of 8 did not include the applicable provisions required by Appendix II to 2 CFR Part 200. Suspension and Debarment: ? 6 out of 8 covered transactions tested did not have evidence that management checked for suspension and debarment during the scope of this audit; by management either not verifying the SAM?s.gov website, not obtaining a certification, or not adding a clause or condition to the covered transaction. Cause: Not following the County?s own official policies and procedures over procurement and suspension and debarment. Effect: Not following the County?s procurement policies and procedures that are in place and required by the Uniform Guidance resulted in noncompliance with the requirements of the program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 vendor contracts from a population of 38 were tested totaling $1,670,639 out of $9,5334,251 of federal program expenditures. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-009. Recommendation: We recommend that the County enforce its official policies and procedures over procurement and suspension and debarment. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases, (ELC) Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance, Material Weakness in Internal Control over Compliance Criteria: Procurement: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. 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. A non-federal entity must: ? Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. ? Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. ? Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements [Davis-Bacon Act]). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). ? Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). ? Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, ?Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.? Suspension and Debarment: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/Home, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition Found: As a result of our audit procedures, we noted the following: Procurement: ? 4 out of 8 transactions tested did not have documentation that full and open competition, price analysis, or rationale to limit competition in those cases where competition was limited. ? 2 out of 8 transactions tested did not have documentation of the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract price in accordance with the Uniform Guidance, section 318(i) and 48 CFR part 44 and section 52.244-2. ? 8 out of 8 did not include the applicable provisions required by Appendix II to 2 CFR Part 200. Suspension and Debarment: ? 6 out of 8 covered transactions tested did not have evidence that management checked for suspension and debarment during the scope of this audit; by management either not verifying the SAM?s.gov website, not obtaining a certification, or not adding a clause or condition to the covered transaction. Cause: Not following the County?s own official policies and procedures over procurement and suspension and debarment. Effect: Not following the County?s procurement policies and procedures that are in place and required by the Uniform Guidance resulted in noncompliance with the requirements of the program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 vendor contracts from a population of 38 were tested totaling $1,670,639 out of $9,5334,251 of federal program expenditures. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-009. Recommendation: We recommend that the County enforce its official policies and procedures over procurement and suspension and debarment. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, COVID-19 National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): SY 2020-2021, SY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations require formal procurement methods when the value of the procurement for property or services exceeds the simplified acquisition threshold (SAT), which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 and provides that the proper purchasing method for supplies over $150,000 would be the bidding process, unless the purchase meets certain other qualifications. Indiana Code also states that purchase requirements may not be artificially divided to qualify as a purchase under $150,000. Sealed bids or competitive proposals were not obtained from an adequate number of sources for one of two vendors that exceeded the simplified acquisition threshold. Additionally, the School Corporation did not verify that two of four vendors were neither suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.320(b) states in part: "Formal procurement methods. When the value of the procurement for property or services under the Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. . . . (ii) If sealed bids are used the following requirements apply: (A) Bids must be solicited from an adequate number of qualified sources . . . (2) Proposals. . . . (i) Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number qualified offerors. . . ." 2 CFR 200.320(c) states: "Noncompetitive procurement. There are specific circumstances in which noncompetitive pro-curement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncom-petitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Indiana Code 5-22-8-1 states: "(a) This chapter applies only to a purchase expected by the purchasing agent to be less than one hundred fifty thousand dollars ($150,000). (b) Purchase requirements may not be artificially divided so as to constitute a small purchase under this chapter." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the Procurement and Suspension and Debarment compli-ance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response When the acquisition of the supplies or services, in the aggregate, are less than the simplified acquisition threshold, set at $150,000, informal procurement methods are allowable. One check was issued to a vendor in the amount of $232,761 for equipment purchased by the School Corporation and installed in a number of school buildings. As the amount spent with the vendor in question was over the simplified acquisition threshold, formal procurement methods should have been utilized. Formal procurement methods would have entailed obtaining sealed bids for the equipment and installation and the awarding of a contract. The award of a contract over $25,000 would have also required the vendor to be verified to ensure that the vendor itself was not excluded or disqualified from participating in federal assistance programs. If the vendor had been excluded or disqualified, federal funds should not have been used to pay the vendor.
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, COVID-19 National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): SY 2020-2021, SY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations require formal procurement methods when the value of the procurement for property or services exceeds the simplified acquisition threshold (SAT), which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 and provides that the proper purchasing method for supplies over $150,000 would be the bidding process, unless the purchase meets certain other qualifications. Indiana Code also states that purchase requirements may not be artificially divided to qualify as a purchase under $150,000. Sealed bids or competitive proposals were not obtained from an adequate number of sources for one of two vendors that exceeded the simplified acquisition threshold. Additionally, the School Corporation did not verify that two of four vendors were neither suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.320(b) states in part: "Formal procurement methods. When the value of the procurement for property or services under the Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. . . . (ii) If sealed bids are used the following requirements apply: (A) Bids must be solicited from an adequate number of qualified sources . . . (2) Proposals. . . . (i) Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number qualified offerors. . . ." 2 CFR 200.320(c) states: "Noncompetitive procurement. There are specific circumstances in which noncompetitive pro-curement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncom-petitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Indiana Code 5-22-8-1 states: "(a) This chapter applies only to a purchase expected by the purchasing agent to be less than one hundred fifty thousand dollars ($150,000). (b) Purchase requirements may not be artificially divided so as to constitute a small purchase under this chapter." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the Procurement and Suspension and Debarment compli-ance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response When the acquisition of the supplies or services, in the aggregate, are less than the simplified acquisition threshold, set at $150,000, informal procurement methods are allowable. One check was issued to a vendor in the amount of $232,761 for equipment purchased by the School Corporation and installed in a number of school buildings. As the amount spent with the vendor in question was over the simplified acquisition threshold, formal procurement methods should have been utilized. Formal procurement methods would have entailed obtaining sealed bids for the equipment and installation and the awarding of a contract. The award of a contract over $25,000 would have also required the vendor to be verified to ensure that the vendor itself was not excluded or disqualified from participating in federal assistance programs. If the vendor had been excluded or disqualified, federal funds should not have been used to pay the vendor.
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, COVID-19 National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): SY 2020-2021, SY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations require formal procurement methods when the value of the procurement for property or services exceeds the simplified acquisition threshold (SAT), which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 and provides that the proper purchasing method for supplies over $150,000 would be the bidding process, unless the purchase meets certain other qualifications. Indiana Code also states that purchase requirements may not be artificially divided to qualify as a purchase under $150,000. Sealed bids or competitive proposals were not obtained from an adequate number of sources for one of two vendors that exceeded the simplified acquisition threshold. Additionally, the School Corporation did not verify that two of four vendors were neither suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.320(b) states in part: "Formal procurement methods. When the value of the procurement for property or services under the Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. . . . (ii) If sealed bids are used the following requirements apply: (A) Bids must be solicited from an adequate number of qualified sources . . . (2) Proposals. . . . (i) Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number qualified offerors. . . ." 2 CFR 200.320(c) states: "Noncompetitive procurement. There are specific circumstances in which noncompetitive pro-curement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncom-petitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Indiana Code 5-22-8-1 states: "(a) This chapter applies only to a purchase expected by the purchasing agent to be less than one hundred fifty thousand dollars ($150,000). (b) Purchase requirements may not be artificially divided so as to constitute a small purchase under this chapter." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the Procurement and Suspension and Debarment compli-ance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response When the acquisition of the supplies or services, in the aggregate, are less than the simplified acquisition threshold, set at $150,000, informal procurement methods are allowable. One check was issued to a vendor in the amount of $232,761 for equipment purchased by the School Corporation and installed in a number of school buildings. As the amount spent with the vendor in question was over the simplified acquisition threshold, formal procurement methods should have been utilized. Formal procurement methods would have entailed obtaining sealed bids for the equipment and installation and the awarding of a contract. The award of a contract over $25,000 would have also required the vendor to be verified to ensure that the vendor itself was not excluded or disqualified from participating in federal assistance programs. If the vendor had been excluded or disqualified, federal funds should not have been used to pay the vendor.