2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
Finding 2022-005: Procurement Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: Astraea's procurement policy references CFR 200.318-327 however the policy does not note how it will comply with the requirements and what the process is to ensure compliance is achieved. During our audit we noted multiple instances where vendors were engaged without any documentation of procurement process or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Astraea does not have a procedure in place to ensure all vendors or suppliers paid with Federal funding are engaged in compliance with the Federal regulations. Context: Without updating the policy to comply with CFR 200, Astraea is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Astraea may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: Yes - 2021-006. Recommendation: We recommend Astraea update the procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.Condition: The College had a procurement policy that conformed to 2 CFR Part 200. Yet, during our testing, we noted that the College?s procurement policies were not followed. There was a single vendor who provided similar goods and services across two grants which had cumulative purchases over $10,000 within the fiscal year. This triggered Small Purchase compliance requirements to be followed; however, there was no documentation to support compliance.Questioned costs: None.Context: We tested a sample of five vendors and noted one vendor had the exception noted above.Cause: The College focused on the individual amounts being charged to the separate grants, not the cumulative amount paid to the vendor for the goods and services being provided.Effect: The College is not in compliance with their policy, nor are they in compliance with the prescribed methods of procurement as outlined in 2 CFR Part 200.320 to ensure reasonable price or rate.Repeat finding: No.Recommendation: We recommend that the College ensure its policies and procedures over procurement are being enforced to ensure reasonable prices and rates. Specifically, the College should consider training employees that regulations do apply when a single vendor is being used for a good or service, yet the charges are split amongst various funding sources.View of responsible official: The College agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Summer FoodService Program, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersRepeat FindingThis is a repeat finding for suspension and debarment from the immediately prior report. The prioraudit finding number was 2020-004.INDIANA STATE BOARD OF ACCOUNTS23BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Federal regulations allow for informal procurement methods when the value of the procurement forproperty 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 or less for when small purchaseprocedures may be used. This informal process allows for methods other than the formal bid process. Theinformal process is divided between two methods based on thresholds. Micro-purchases, typically for thosepurchases $10,000 or under, and small purchase procedures for those purchases above the micropurchasethreshold, but below the simplified acquisition threshold. Micro-purchases may be awardedwithout soliciting competitive price rate quotations. If small purchase procedures are used, then price orrate quotations must be obtained from an adequate number of qualified sources.The School Corporation did not obtain price or rate quotes for six vendors tested that were lessthan 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 documentationthat the threshold had been increased.The School Corporation engaged with an Education Service Center that was not an approvedSchool Food Authority (SFA) cooperative. Since the Education Service Center failed to meet therequirements to be an approved SFA cooperative, the obligation reverted to the School Corporation. TheSchool Corporation did not obtain price or rate quotes for purchases of milk, exceeding $10,000 from anadequate number of sources, which fell under the small purchase procedures. In addition, the SchoolCorporation did not verify the milk vendor with a contract over $25,000 was not excluded or disqualifiedfrom participation in federal award programs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 themethod of procurement, selection of contract type, contractor selection or rejection, and thebasis for the contract price."INDIANA STATE BOARD OF ACCOUNTS24BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.320(b) (Uniform Guidance) states:"Procurement by small purchase procedures. Small purchase procedures are those relativelysimple and informal procurement methods for securing services, supplies, or other propertythat do not cost more than the Simplified Acquisition Threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number of qualifiedsources."2 CFR 200.320 (Revised Uniform Guidance) states in part:"The non-Federal entity must have and use document procurement procedures, consistent withthe standards of this section and ?? 200.317, 200.318, and 200.319 for any of the followingmethods of procurement used for the acquisition of property or services required under aFederal award or sub-award.(a) Informal procurement methods. When the value of the procurement for property orservices 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 informalprocurement methods to expedite the completion of its transactions and minimize theassociated administrative burden and cost. The informal methods used for procurementof property or services at or below the SAT include: . . .(2) Small purchases ?(i) Small purchase procedures. The acquisition of property or services, theaggregate dollar amount of which is higher than the micro-purchase threshold butdoes not exceed the simplified acquisition threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number ofqualified sources as determined appropriate by the non-Federal entity. . . ."Indiana Code 5-22-8-3 states:"(a) This section applies only if the purchasing agent expects the purchase to be:(1) at least fifty thousand dollars ($50,000); and(2) not more than one hundred fifty thousand dollars ($150,000). . . ."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Procurement and Suspension and Debarment compliance requirement.EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement could result in the loss of future federal funds to the School Corporation.INDIANA STATE BOARD OF ACCOUNTS25BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Summer FoodService Program, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersRepeat FindingThis is a repeat finding for suspension and debarment from the immediately prior report. The prioraudit finding number was 2020-004.INDIANA STATE BOARD OF ACCOUNTS23BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Federal regulations allow for informal procurement methods when the value of the procurement forproperty 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 or less for when small purchaseprocedures may be used. This informal process allows for methods other than the formal bid process. Theinformal process is divided between two methods based on thresholds. Micro-purchases, typically for thosepurchases $10,000 or under, and small purchase procedures for those purchases above the micropurchasethreshold, but below the simplified acquisition threshold. Micro-purchases may be awardedwithout soliciting competitive price rate quotations. If small purchase procedures are used, then price orrate quotations must be obtained from an adequate number of qualified sources.The School Corporation did not obtain price or rate quotes for six vendors tested that were lessthan 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 documentationthat the threshold had been increased.The School Corporation engaged with an Education Service Center that was not an approvedSchool Food Authority (SFA) cooperative. Since the Education Service Center failed to meet therequirements to be an approved SFA cooperative, the obligation reverted to the School Corporation. TheSchool Corporation did not obtain price or rate quotes for purchases of milk, exceeding $10,000 from anadequate number of sources, which fell under the small purchase procedures. In addition, the SchoolCorporation did not verify the milk vendor with a contract over $25,000 was not excluded or disqualifiedfrom participation in federal award programs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 themethod of procurement, selection of contract type, contractor selection or rejection, and thebasis for the contract price."INDIANA STATE BOARD OF ACCOUNTS24BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.320(b) (Uniform Guidance) states:"Procurement by small purchase procedures. Small purchase procedures are those relativelysimple and informal procurement methods for securing services, supplies, or other propertythat do not cost more than the Simplified Acquisition Threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number of qualifiedsources."2 CFR 200.320 (Revised Uniform Guidance) states in part:"The non-Federal entity must have and use document procurement procedures, consistent withthe standards of this section and ?? 200.317, 200.318, and 200.319 for any of the followingmethods of procurement used for the acquisition of property or services required under aFederal award or sub-award.(a) Informal procurement methods. When the value of the procurement for property orservices 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 informalprocurement methods to expedite the completion of its transactions and minimize theassociated administrative burden and cost. The informal methods used for procurementof property or services at or below the SAT include: . . .(2) Small purchases ?(i) Small purchase procedures. The acquisition of property or services, theaggregate dollar amount of which is higher than the micro-purchase threshold butdoes not exceed the simplified acquisition threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number ofqualified sources as determined appropriate by the non-Federal entity. . . ."Indiana Code 5-22-8-3 states:"(a) This section applies only if the purchasing agent expects the purchase to be:(1) at least fifty thousand dollars ($50,000); and(2) not more than one hundred fifty thousand dollars ($150,000). . . ."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Procurement and Suspension and Debarment compliance requirement.EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement could result in the loss of future federal funds to the School Corporation.INDIANA STATE BOARD OF ACCOUNTS25BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Summer FoodService Program, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersRepeat FindingThis is a repeat finding for suspension and debarment from the immediately prior report. The prioraudit finding number was 2020-004.INDIANA STATE BOARD OF ACCOUNTS23BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Federal regulations allow for informal procurement methods when the value of the procurement forproperty 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 or less for when small purchaseprocedures may be used. This informal process allows for methods other than the formal bid process. Theinformal process is divided between two methods based on thresholds. Micro-purchases, typically for thosepurchases $10,000 or under, and small purchase procedures for those purchases above the micropurchasethreshold, but below the simplified acquisition threshold. Micro-purchases may be awardedwithout soliciting competitive price rate quotations. If small purchase procedures are used, then price orrate quotations must be obtained from an adequate number of qualified sources.The School Corporation did not obtain price or rate quotes for six vendors tested that were lessthan 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 documentationthat the threshold had been increased.The School Corporation engaged with an Education Service Center that was not an approvedSchool Food Authority (SFA) cooperative. Since the Education Service Center failed to meet therequirements to be an approved SFA cooperative, the obligation reverted to the School Corporation. TheSchool Corporation did not obtain price or rate quotes for purchases of milk, exceeding $10,000 from anadequate number of sources, which fell under the small purchase procedures. In addition, the SchoolCorporation did not verify the milk vendor with a contract over $25,000 was not excluded or disqualifiedfrom participation in federal award programs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 themethod of procurement, selection of contract type, contractor selection or rejection, and thebasis for the contract price."INDIANA STATE BOARD OF ACCOUNTS24BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.320(b) (Uniform Guidance) states:"Procurement by small purchase procedures. Small purchase procedures are those relativelysimple and informal procurement methods for securing services, supplies, or other propertythat do not cost more than the Simplified Acquisition Threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number of qualifiedsources."2 CFR 200.320 (Revised Uniform Guidance) states in part:"The non-Federal entity must have and use document procurement procedures, consistent withthe standards of this section and ?? 200.317, 200.318, and 200.319 for any of the followingmethods of procurement used for the acquisition of property or services required under aFederal award or sub-award.(a) Informal procurement methods. When the value of the procurement for property orservices 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 informalprocurement methods to expedite the completion of its transactions and minimize theassociated administrative burden and cost. The informal methods used for procurementof property or services at or below the SAT include: . . .(2) Small purchases ?(i) Small purchase procedures. The acquisition of property or services, theaggregate dollar amount of which is higher than the micro-purchase threshold butdoes not exceed the simplified acquisition threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number ofqualified sources as determined appropriate by the non-Federal entity. . . ."Indiana Code 5-22-8-3 states:"(a) This section applies only if the purchasing agent expects the purchase to be:(1) at least fifty thousand dollars ($50,000); and(2) not more than one hundred fifty thousand dollars ($150,000). . . ."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Procurement and Suspension and Debarment compliance requirement.EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement could result in the loss of future federal funds to the School Corporation.INDIANA STATE BOARD OF ACCOUNTS25BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Summer FoodService Program, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersRepeat FindingThis is a repeat finding for suspension and debarment from the immediately prior report. The prioraudit finding number was 2020-004.INDIANA STATE BOARD OF ACCOUNTS23BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Federal regulations allow for informal procurement methods when the value of the procurement forproperty 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 or less for when small purchaseprocedures may be used. This informal process allows for methods other than the formal bid process. Theinformal process is divided between two methods based on thresholds. Micro-purchases, typically for thosepurchases $10,000 or under, and small purchase procedures for those purchases above the micropurchasethreshold, but below the simplified acquisition threshold. Micro-purchases may be awardedwithout soliciting competitive price rate quotations. If small purchase procedures are used, then price orrate quotations must be obtained from an adequate number of qualified sources.The School Corporation did not obtain price or rate quotes for six vendors tested that were lessthan 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 documentationthat the threshold had been increased.The School Corporation engaged with an Education Service Center that was not an approvedSchool Food Authority (SFA) cooperative. Since the Education Service Center failed to meet therequirements to be an approved SFA cooperative, the obligation reverted to the School Corporation. TheSchool Corporation did not obtain price or rate quotes for purchases of milk, exceeding $10,000 from anadequate number of sources, which fell under the small purchase procedures. In addition, the SchoolCorporation did not verify the milk vendor with a contract over $25,000 was not excluded or disqualifiedfrom participation in federal award programs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 themethod of procurement, selection of contract type, contractor selection or rejection, and thebasis for the contract price."INDIANA STATE BOARD OF ACCOUNTS24BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.320(b) (Uniform Guidance) states:"Procurement by small purchase procedures. Small purchase procedures are those relativelysimple and informal procurement methods for securing services, supplies, or other propertythat do not cost more than the Simplified Acquisition Threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number of qualifiedsources."2 CFR 200.320 (Revised Uniform Guidance) states in part:"The non-Federal entity must have and use document procurement procedures, consistent withthe standards of this section and ?? 200.317, 200.318, and 200.319 for any of the followingmethods of procurement used for the acquisition of property or services required under aFederal award or sub-award.(a) Informal procurement methods. When the value of the procurement for property orservices 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 informalprocurement methods to expedite the completion of its transactions and minimize theassociated administrative burden and cost. The informal methods used for procurementof property or services at or below the SAT include: . . .(2) Small purchases ?(i) Small purchase procedures. The acquisition of property or services, theaggregate dollar amount of which is higher than the micro-purchase threshold butdoes not exceed the simplified acquisition threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number ofqualified sources as determined appropriate by the non-Federal entity. . . ."Indiana Code 5-22-8-3 states:"(a) This section applies only if the purchasing agent expects the purchase to be:(1) at least fifty thousand dollars ($50,000); and(2) not more than one hundred fifty thousand dollars ($150,000). . . ."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Procurement and Suspension and Debarment compliance requirement.EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement could result in the loss of future federal funds to the School Corporation.INDIANA STATE BOARD OF ACCOUNTS25BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Summer FoodService Program, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersRepeat FindingThis is a repeat finding for suspension and debarment from the immediately prior report. The prioraudit finding number was 2020-004.INDIANA STATE BOARD OF ACCOUNTS23BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Federal regulations allow for informal procurement methods when the value of the procurement forproperty 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 or less for when small purchaseprocedures may be used. This informal process allows for methods other than the formal bid process. Theinformal process is divided between two methods based on thresholds. Micro-purchases, typically for thosepurchases $10,000 or under, and small purchase procedures for those purchases above the micropurchasethreshold, but below the simplified acquisition threshold. Micro-purchases may be awardedwithout soliciting competitive price rate quotations. If small purchase procedures are used, then price orrate quotations must be obtained from an adequate number of qualified sources.The School Corporation did not obtain price or rate quotes for six vendors tested that were lessthan 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 documentationthat the threshold had been increased.The School Corporation engaged with an Education Service Center that was not an approvedSchool Food Authority (SFA) cooperative. Since the Education Service Center failed to meet therequirements to be an approved SFA cooperative, the obligation reverted to the School Corporation. TheSchool Corporation did not obtain price or rate quotes for purchases of milk, exceeding $10,000 from anadequate number of sources, which fell under the small purchase procedures. In addition, the SchoolCorporation did not verify the milk vendor with a contract over $25,000 was not excluded or disqualifiedfrom participation in federal award programs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 themethod of procurement, selection of contract type, contractor selection or rejection, and thebasis for the contract price."INDIANA STATE BOARD OF ACCOUNTS24BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.320(b) (Uniform Guidance) states:"Procurement by small purchase procedures. Small purchase procedures are those relativelysimple and informal procurement methods for securing services, supplies, or other propertythat do not cost more than the Simplified Acquisition Threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number of qualifiedsources."2 CFR 200.320 (Revised Uniform Guidance) states in part:"The non-Federal entity must have and use document procurement procedures, consistent withthe standards of this section and ?? 200.317, 200.318, and 200.319 for any of the followingmethods of procurement used for the acquisition of property or services required under aFederal award or sub-award.(a) Informal procurement methods. When the value of the procurement for property orservices 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 informalprocurement methods to expedite the completion of its transactions and minimize theassociated administrative burden and cost. The informal methods used for procurementof property or services at or below the SAT include: . . .(2) Small purchases ?(i) Small purchase procedures. The acquisition of property or services, theaggregate dollar amount of which is higher than the micro-purchase threshold butdoes not exceed the simplified acquisition threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number ofqualified sources as determined appropriate by the non-Federal entity. . . ."Indiana Code 5-22-8-3 states:"(a) This section applies only if the purchasing agent expects the purchase to be:(1) at least fifty thousand dollars ($50,000); and(2) not more than one hundred fifty thousand dollars ($150,000). . . ."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Procurement and Suspension and Debarment compliance requirement.EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement could result in the loss of future federal funds to the School Corporation.INDIANA STATE BOARD OF ACCOUNTS25BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Summer FoodService Program, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersRepeat FindingThis is a repeat finding for suspension and debarment from the immediately prior report. The prioraudit finding number was 2020-004.INDIANA STATE BOARD OF ACCOUNTS23BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Federal regulations allow for informal procurement methods when the value of the procurement forproperty 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 or less for when small purchaseprocedures may be used. This informal process allows for methods other than the formal bid process. Theinformal process is divided between two methods based on thresholds. Micro-purchases, typically for thosepurchases $10,000 or under, and small purchase procedures for those purchases above the micropurchasethreshold, but below the simplified acquisition threshold. Micro-purchases may be awardedwithout soliciting competitive price rate quotations. If small purchase procedures are used, then price orrate quotations must be obtained from an adequate number of qualified sources.The School Corporation did not obtain price or rate quotes for six vendors tested that were lessthan 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 documentationthat the threshold had been increased.The School Corporation engaged with an Education Service Center that was not an approvedSchool Food Authority (SFA) cooperative. Since the Education Service Center failed to meet therequirements to be an approved SFA cooperative, the obligation reverted to the School Corporation. TheSchool Corporation did not obtain price or rate quotes for purchases of milk, exceeding $10,000 from anadequate number of sources, which fell under the small purchase procedures. In addition, the SchoolCorporation did not verify the milk vendor with a contract over $25,000 was not excluded or disqualifiedfrom participation in federal award programs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 themethod of procurement, selection of contract type, contractor selection or rejection, and thebasis for the contract price."INDIANA STATE BOARD OF ACCOUNTS24BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.320(b) (Uniform Guidance) states:"Procurement by small purchase procedures. Small purchase procedures are those relativelysimple and informal procurement methods for securing services, supplies, or other propertythat do not cost more than the Simplified Acquisition Threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number of qualifiedsources."2 CFR 200.320 (Revised Uniform Guidance) states in part:"The non-Federal entity must have and use document procurement procedures, consistent withthe standards of this section and ?? 200.317, 200.318, and 200.319 for any of the followingmethods of procurement used for the acquisition of property or services required under aFederal award or sub-award.(a) Informal procurement methods. When the value of the procurement for property orservices 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 informalprocurement methods to expedite the completion of its transactions and minimize theassociated administrative burden and cost. The informal methods used for procurementof property or services at or below the SAT include: . . .(2) Small purchases ?(i) Small purchase procedures. The acquisition of property or services, theaggregate dollar amount of which is higher than the micro-purchase threshold butdoes not exceed the simplified acquisition threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number ofqualified sources as determined appropriate by the non-Federal entity. . . ."Indiana Code 5-22-8-3 states:"(a) This section applies only if the purchasing agent expects the purchase to be:(1) at least fifty thousand dollars ($50,000); and(2) not more than one hundred fifty thousand dollars ($150,000). . . ."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Procurement and Suspension and Debarment compliance requirement.EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement could result in the loss of future federal funds to the School Corporation.INDIANA STATE BOARD OF ACCOUNTS25BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Summer FoodService Program, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersRepeat FindingThis is a repeat finding for suspension and debarment from the immediately prior report. The prioraudit finding number was 2020-004.INDIANA STATE BOARD OF ACCOUNTS23BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Federal regulations allow for informal procurement methods when the value of the procurement forproperty 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 or less for when small purchaseprocedures may be used. This informal process allows for methods other than the formal bid process. Theinformal process is divided between two methods based on thresholds. Micro-purchases, typically for thosepurchases $10,000 or under, and small purchase procedures for those purchases above the micropurchasethreshold, but below the simplified acquisition threshold. Micro-purchases may be awardedwithout soliciting competitive price rate quotations. If small purchase procedures are used, then price orrate quotations must be obtained from an adequate number of qualified sources.The School Corporation did not obtain price or rate quotes for six vendors tested that were lessthan 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 documentationthat the threshold had been increased.The School Corporation engaged with an Education Service Center that was not an approvedSchool Food Authority (SFA) cooperative. Since the Education Service Center failed to meet therequirements to be an approved SFA cooperative, the obligation reverted to the School Corporation. TheSchool Corporation did not obtain price or rate quotes for purchases of milk, exceeding $10,000 from anadequate number of sources, which fell under the small purchase procedures. In addition, the SchoolCorporation did not verify the milk vendor with a contract over $25,000 was not excluded or disqualifiedfrom participation in federal award programs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 themethod of procurement, selection of contract type, contractor selection or rejection, and thebasis for the contract price."INDIANA STATE BOARD OF ACCOUNTS24BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.320(b) (Uniform Guidance) states:"Procurement by small purchase procedures. Small purchase procedures are those relativelysimple and informal procurement methods for securing services, supplies, or other propertythat do not cost more than the Simplified Acquisition Threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number of qualifiedsources."2 CFR 200.320 (Revised Uniform Guidance) states in part:"The non-Federal entity must have and use document procurement procedures, consistent withthe standards of this section and ?? 200.317, 200.318, and 200.319 for any of the followingmethods of procurement used for the acquisition of property or services required under aFederal award or sub-award.(a) Informal procurement methods. When the value of the procurement for property orservices 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 informalprocurement methods to expedite the completion of its transactions and minimize theassociated administrative burden and cost. The informal methods used for procurementof property or services at or below the SAT include: . . .(2) Small purchases ?(i) Small purchase procedures. The acquisition of property or services, theaggregate dollar amount of which is higher than the micro-purchase threshold butdoes not exceed the simplified acquisition threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number ofqualified sources as determined appropriate by the non-Federal entity. . . ."Indiana Code 5-22-8-3 states:"(a) This section applies only if the purchasing agent expects the purchase to be:(1) at least fifty thousand dollars ($50,000); and(2) not more than one hundred fifty thousand dollars ($150,000). . . ."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Procurement and Suspension and Debarment compliance requirement.EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement could result in the loss of future federal funds to the School Corporation.INDIANA STATE BOARD OF ACCOUNTS25BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Summer FoodService Program, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersRepeat FindingThis is a repeat finding for suspension and debarment from the immediately prior report. The prioraudit finding number was 2020-004.INDIANA STATE BOARD OF ACCOUNTS23BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Federal regulations allow for informal procurement methods when the value of the procurement forproperty 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 or less for when small purchaseprocedures may be used. This informal process allows for methods other than the formal bid process. Theinformal process is divided between two methods based on thresholds. Micro-purchases, typically for thosepurchases $10,000 or under, and small purchase procedures for those purchases above the micropurchasethreshold, but below the simplified acquisition threshold. Micro-purchases may be awardedwithout soliciting competitive price rate quotations. If small purchase procedures are used, then price orrate quotations must be obtained from an adequate number of qualified sources.The School Corporation did not obtain price or rate quotes for six vendors tested that were lessthan 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 documentationthat the threshold had been increased.The School Corporation engaged with an Education Service Center that was not an approvedSchool Food Authority (SFA) cooperative. Since the Education Service Center failed to meet therequirements to be an approved SFA cooperative, the obligation reverted to the School Corporation. TheSchool Corporation did not obtain price or rate quotes for purchases of milk, exceeding $10,000 from anadequate number of sources, which fell under the small purchase procedures. In addition, the SchoolCorporation did not verify the milk vendor with a contract over $25,000 was not excluded or disqualifiedfrom participation in federal award programs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 themethod of procurement, selection of contract type, contractor selection or rejection, and thebasis for the contract price."INDIANA STATE BOARD OF ACCOUNTS24BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.320(b) (Uniform Guidance) states:"Procurement by small purchase procedures. Small purchase procedures are those relativelysimple and informal procurement methods for securing services, supplies, or other propertythat do not cost more than the Simplified Acquisition Threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number of qualifiedsources."2 CFR 200.320 (Revised Uniform Guidance) states in part:"The non-Federal entity must have and use document procurement procedures, consistent withthe standards of this section and ?? 200.317, 200.318, and 200.319 for any of the followingmethods of procurement used for the acquisition of property or services required under aFederal award or sub-award.(a) Informal procurement methods. When the value of the procurement for property orservices 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 informalprocurement methods to expedite the completion of its transactions and minimize theassociated administrative burden and cost. The informal methods used for procurementof property or services at or below the SAT include: . . .(2) Small purchases ?(i) Small purchase procedures. The acquisition of property or services, theaggregate dollar amount of which is higher than the micro-purchase threshold butdoes not exceed the simplified acquisition threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number ofqualified sources as determined appropriate by the non-Federal entity. . . ."Indiana Code 5-22-8-3 states:"(a) This section applies only if the purchasing agent expects the purchase to be:(1) at least fifty thousand dollars ($50,000); and(2) not more than one hundred fifty thousand dollars ($150,000). . . ."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Procurement and Suspension and Debarment compliance requirement.EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement could result in the loss of future federal funds to the School Corporation.INDIANA STATE BOARD OF ACCOUNTS25BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Summer FoodService Program, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersRepeat FindingThis is a repeat finding for suspension and debarment from the immediately prior report. The prioraudit finding number was 2020-004.INDIANA STATE BOARD OF ACCOUNTS23BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Federal regulations allow for informal procurement methods when the value of the procurement forproperty 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 or less for when small purchaseprocedures may be used. This informal process allows for methods other than the formal bid process. Theinformal process is divided between two methods based on thresholds. Micro-purchases, typically for thosepurchases $10,000 or under, and small purchase procedures for those purchases above the micropurchasethreshold, but below the simplified acquisition threshold. Micro-purchases may be awardedwithout soliciting competitive price rate quotations. If small purchase procedures are used, then price orrate quotations must be obtained from an adequate number of qualified sources.The School Corporation did not obtain price or rate quotes for six vendors tested that were lessthan 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 documentationthat the threshold had been increased.The School Corporation engaged with an Education Service Center that was not an approvedSchool Food Authority (SFA) cooperative. Since the Education Service Center failed to meet therequirements to be an approved SFA cooperative, the obligation reverted to the School Corporation. TheSchool Corporation did not obtain price or rate quotes for purchases of milk, exceeding $10,000 from anadequate number of sources, which fell under the small purchase procedures. In addition, the SchoolCorporation did not verify the milk vendor with a contract over $25,000 was not excluded or disqualifiedfrom participation in federal award programs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 themethod of procurement, selection of contract type, contractor selection or rejection, and thebasis for the contract price."INDIANA STATE BOARD OF ACCOUNTS24BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.320(b) (Uniform Guidance) states:"Procurement by small purchase procedures. Small purchase procedures are those relativelysimple and informal procurement methods for securing services, supplies, or other propertythat do not cost more than the Simplified Acquisition Threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number of qualifiedsources."2 CFR 200.320 (Revised Uniform Guidance) states in part:"The non-Federal entity must have and use document procurement procedures, consistent withthe standards of this section and ?? 200.317, 200.318, and 200.319 for any of the followingmethods of procurement used for the acquisition of property or services required under aFederal award or sub-award.(a) Informal procurement methods. When the value of the procurement for property orservices 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 informalprocurement methods to expedite the completion of its transactions and minimize theassociated administrative burden and cost. The informal methods used for procurementof property or services at or below the SAT include: . . .(2) Small purchases ?(i) Small purchase procedures. The acquisition of property or services, theaggregate dollar amount of which is higher than the micro-purchase threshold butdoes not exceed the simplified acquisition threshold. If small purchase proceduresare used, price or rate quotations must be obtained from an adequate number ofqualified sources as determined appropriate by the non-Federal entity. . . ."Indiana Code 5-22-8-3 states:"(a) This section applies only if the purchasing agent expects the purchase to be:(1) at least fifty thousand dollars ($50,000); and(2) not more than one hundred fifty thousand dollars ($150,000). . . ."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Procurement and Suspension and Debarment compliance requirement.EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement could result in the loss of future federal funds to the School Corporation.INDIANA STATE BOARD OF ACCOUNTS25BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Procurement and Suspension andDebarment compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2022-018 ? Procurement and Suspension and DebarmentIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, and 93.853See Schedule of Findings and Questioned Costs for chart/tableSt. Joseph?s Hospital and Medical CenterCriteria or specific requirement (including statutory, regulatory, orother citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR 200.318 (i) General Procurement Standards 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.?Criteria or specific requirement (including statutory, regulatory, orother citation) (continued) 2 CFR 200.320 (c) Noncompetitive procurement states, ?there are specific circumstances in which noncompetitive procurement 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 noncompetitive 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.?Condition St. Joseph?s Hospital and Medical Center did not prepare and retain documentation of sole source justification for three procurements over the micro-purchase threshold made without competition.Cause St. Joseph?s Hospital and Medical Center did not have effective internal controls over preparation and retention of the rationale of the method of procurement.Effect or potential effect Noncompliance with the procurement documentation requirements of 2 CFR 200.318 (i) and without adequate documentation of sole source justification there is greater potential for noncompliance with noncompetitive procurement requirements in 2 CFR 200.320 (c).Questioned costs None.Context For 3 of 5 procurements selected for testing, St. Joseph?s Hospital and Medical Center indicated the procurement was a noncompetitive procurement (sole source) but did not have documentation to support the rationale for the sole source procurement.We selected and tested five procurements with expenditures totaling $151,515 from a population of 6 procurements with expenditures totaling $161,960 charged to the St. Joseph?s Hospital and Medical Center during the year ended June 30, 2022. The three noncompetitive procurements tested totaled $43,356.Identification as a repeat finding, if applicable This is not a repeat finding.Recommendation St. Joseph?s Hospital and Medical Center should retain written documentation for procurements documenting the history of the procurement prior to the procurement of goods or services, including, but not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.Views of responsibleofficials Management agrees with the finding and will implement corrective action by April 2023.
Finding 2022-018 ? Procurement and Suspension and DebarmentIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, and 93.853See Schedule of Findings and Questioned Costs for chart/tableSt. Joseph?s Hospital and Medical CenterCriteria or specific requirement (including statutory, regulatory, orother citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR 200.318 (i) General Procurement Standards 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.?Criteria or specific requirement (including statutory, regulatory, orother citation) (continued) 2 CFR 200.320 (c) Noncompetitive procurement states, ?there are specific circumstances in which noncompetitive procurement 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 noncompetitive 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.?Condition St. Joseph?s Hospital and Medical Center did not prepare and retain documentation of sole source justification for three procurements over the micro-purchase threshold made without competition.Cause St. Joseph?s Hospital and Medical Center did not have effective internal controls over preparation and retention of the rationale of the method of procurement.Effect or potential effect Noncompliance with the procurement documentation requirements of 2 CFR 200.318 (i) and without adequate documentation of sole source justification there is greater potential for noncompliance with noncompetitive procurement requirements in 2 CFR 200.320 (c).Questioned costs None.Context For 3 of 5 procurements selected for testing, St. Joseph?s Hospital and Medical Center indicated the procurement was a noncompetitive procurement (sole source) but did not have documentation to support the rationale for the sole source procurement.We selected and tested five procurements with expenditures totaling $151,515 from a population of 6 procurements with expenditures totaling $161,960 charged to the St. Joseph?s Hospital and Medical Center during the year ended June 30, 2022. The three noncompetitive procurements tested totaled $43,356.Identification as a repeat finding, if applicable This is not a repeat finding.Recommendation St. Joseph?s Hospital and Medical Center should retain written documentation for procurements documenting the history of the procurement prior to the procurement of goods or services, including, but not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.Views of responsibleofficials Management agrees with the finding and will implement corrective action by April 2023.