Repeat finding 2023-001, 2022-001, and 2021-002 FAN 93.676 Unaccompanied Alien Children Program Child Nutrition Cluster Procurement and Suspension & Debarment Type of Finding: Non-Compliance U.S. Department of Health & Human Services U.S Department of Agriculture Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: 1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. 3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.” The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. The requirements for non-procurement suspension and debarment are contained in OMB guidance in 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension;” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition The Organization had no findings for contracts procured during the last three fiscal years that were detail tested. However, the Organization’s management recognizes that there are still active contracts under the federal programs for fiscal year ending August 31, 2024 that were procured over three fiscal years ago in which adherence to procurement policies, specifically documentation history of procurement, has not been maintained. In regards to progress made in reducing the number of vendors that are out of compliance, specifically vendors with over $50,000 of annual expenditures that were categorized as “legacy” vendors procured under the previous procurement policies, the Organization went from having 100 vendors totaling approximately $159 million in expenditures as of August 31, 2023, to 46 vendors totaling approximately $119 million as of August 31, 2024. This shows a decrease of 54% in the number of legacy vendors with a decrease of 25% in the dollar-value of the legacy vendors year over year. Further, the Organization continues to make progress in reducing legacy vendor non-compliance by reducing that number to 33 vendors totaling approximately $113 million as of January 2, 2025. As this has been a recurring finding in which management is actively getting all active contracts under the current procurement policies, only those current contracts that were procured in the last three fiscal years were detail tested. Of the approximately 70 active vendor contracts that were procured in the last three fiscal years that were wholly or partially funded with Unaccompanied Alien Children Program revenue dollars or with Child Nutrition Cluster Program revenue dollars, ten were tested with no errors noted. Cause The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Contracts procured within the last three years show compliance with federal requirements based on detailed testing. Reprocuring all of the legacy contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. As such, the Organization still has active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Effect or Potential Effect The Organization could potentially be under contract with vendors that are not the best value, not adequately qualified, potentially suspended or debarred, or otherwise not suitable for contract under federal procurement guidelines. No questioned costs were identified, as services/goods under these contracts that were previously tested were deemed to be allowable under the program, and no exceptions noted for allowable costs/activities for samples that included payment to those vendors in previous years or current year. Recommendation The Organization should continue to review all its “legacy” contracts that were procured under the previous procurement policies to determine if there is proper documentation maintained for compliance with applicable procurement guidelines. This includes systematically re-procuring any current contracts not in compliance as soon as feasible. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.
Repeat finding 2023-001, 2022-001, and 2021-002 FAN 93.676 Unaccompanied Alien Children Program Child Nutrition Cluster Procurement and Suspension & Debarment Type of Finding: Non-Compliance U.S. Department of Health & Human Services U.S Department of Agriculture Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: 1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. 3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.” The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. The requirements for non-procurement suspension and debarment are contained in OMB guidance in 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension;” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition The Organization had no findings for contracts procured during the last three fiscal years that were detail tested. However, the Organization’s management recognizes that there are still active contracts under the federal programs for fiscal year ending August 31, 2024 that were procured over three fiscal years ago in which adherence to procurement policies, specifically documentation history of procurement, has not been maintained. In regards to progress made in reducing the number of vendors that are out of compliance, specifically vendors with over $50,000 of annual expenditures that were categorized as “legacy” vendors procured under the previous procurement policies, the Organization went from having 100 vendors totaling approximately $159 million in expenditures as of August 31, 2023, to 46 vendors totaling approximately $119 million as of August 31, 2024. This shows a decrease of 54% in the number of legacy vendors with a decrease of 25% in the dollar-value of the legacy vendors year over year. Further, the Organization continues to make progress in reducing legacy vendor non-compliance by reducing that number to 33 vendors totaling approximately $113 million as of January 2, 2025. As this has been a recurring finding in which management is actively getting all active contracts under the current procurement policies, only those current contracts that were procured in the last three fiscal years were detail tested. Of the approximately 70 active vendor contracts that were procured in the last three fiscal years that were wholly or partially funded with Unaccompanied Alien Children Program revenue dollars or with Child Nutrition Cluster Program revenue dollars, ten were tested with no errors noted. Cause The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Contracts procured within the last three years show compliance with federal requirements based on detailed testing. Reprocuring all of the legacy contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. As such, the Organization still has active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Effect or Potential Effect The Organization could potentially be under contract with vendors that are not the best value, not adequately qualified, potentially suspended or debarred, or otherwise not suitable for contract under federal procurement guidelines. No questioned costs were identified, as services/goods under these contracts that were previously tested were deemed to be allowable under the program, and no exceptions noted for allowable costs/activities for samples that included payment to those vendors in previous years or current year. Recommendation The Organization should continue to review all its “legacy” contracts that were procured under the previous procurement policies to determine if there is proper documentation maintained for compliance with applicable procurement guidelines. This includes systematically re-procuring any current contracts not in compliance as soon as feasible. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.
Repeat finding 2023-001, 2022-001, and 2021-002 FAN 93.676 Unaccompanied Alien Children Program Child Nutrition Cluster Procurement and Suspension & Debarment Type of Finding: Non-Compliance U.S. Department of Health & Human Services U.S Department of Agriculture Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: 1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. 3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.” The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. The requirements for non-procurement suspension and debarment are contained in OMB guidance in 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension;” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition The Organization had no findings for contracts procured during the last three fiscal years that were detail tested. However, the Organization’s management recognizes that there are still active contracts under the federal programs for fiscal year ending August 31, 2024 that were procured over three fiscal years ago in which adherence to procurement policies, specifically documentation history of procurement, has not been maintained. In regards to progress made in reducing the number of vendors that are out of compliance, specifically vendors with over $50,000 of annual expenditures that were categorized as “legacy” vendors procured under the previous procurement policies, the Organization went from having 100 vendors totaling approximately $159 million in expenditures as of August 31, 2023, to 46 vendors totaling approximately $119 million as of August 31, 2024. This shows a decrease of 54% in the number of legacy vendors with a decrease of 25% in the dollar-value of the legacy vendors year over year. Further, the Organization continues to make progress in reducing legacy vendor non-compliance by reducing that number to 33 vendors totaling approximately $113 million as of January 2, 2025. As this has been a recurring finding in which management is actively getting all active contracts under the current procurement policies, only those current contracts that were procured in the last three fiscal years were detail tested. Of the approximately 70 active vendor contracts that were procured in the last three fiscal years that were wholly or partially funded with Unaccompanied Alien Children Program revenue dollars or with Child Nutrition Cluster Program revenue dollars, ten were tested with no errors noted. Cause The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Contracts procured within the last three years show compliance with federal requirements based on detailed testing. Reprocuring all of the legacy contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. As such, the Organization still has active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Effect or Potential Effect The Organization could potentially be under contract with vendors that are not the best value, not adequately qualified, potentially suspended or debarred, or otherwise not suitable for contract under federal procurement guidelines. No questioned costs were identified, as services/goods under these contracts that were previously tested were deemed to be allowable under the program, and no exceptions noted for allowable costs/activities for samples that included payment to those vendors in previous years or current year. Recommendation The Organization should continue to review all its “legacy” contracts that were procured under the previous procurement policies to determine if there is proper documentation maintained for compliance with applicable procurement guidelines. This includes systematically re-procuring any current contracts not in compliance as soon as feasible. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.
Repeat finding 2023-001, 2022-001, and 2021-002 FAN 93.676 Unaccompanied Alien Children Program Child Nutrition Cluster Procurement and Suspension & Debarment Type of Finding: Non-Compliance U.S. Department of Health & Human Services U.S Department of Agriculture Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: 1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. 3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.” The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. The requirements for non-procurement suspension and debarment are contained in OMB guidance in 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension;” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition The Organization had no findings for contracts procured during the last three fiscal years that were detail tested. However, the Organization’s management recognizes that there are still active contracts under the federal programs for fiscal year ending August 31, 2024 that were procured over three fiscal years ago in which adherence to procurement policies, specifically documentation history of procurement, has not been maintained. In regards to progress made in reducing the number of vendors that are out of compliance, specifically vendors with over $50,000 of annual expenditures that were categorized as “legacy” vendors procured under the previous procurement policies, the Organization went from having 100 vendors totaling approximately $159 million in expenditures as of August 31, 2023, to 46 vendors totaling approximately $119 million as of August 31, 2024. This shows a decrease of 54% in the number of legacy vendors with a decrease of 25% in the dollar-value of the legacy vendors year over year. Further, the Organization continues to make progress in reducing legacy vendor non-compliance by reducing that number to 33 vendors totaling approximately $113 million as of January 2, 2025. As this has been a recurring finding in which management is actively getting all active contracts under the current procurement policies, only those current contracts that were procured in the last three fiscal years were detail tested. Of the approximately 70 active vendor contracts that were procured in the last three fiscal years that were wholly or partially funded with Unaccompanied Alien Children Program revenue dollars or with Child Nutrition Cluster Program revenue dollars, ten were tested with no errors noted. Cause The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Contracts procured within the last three years show compliance with federal requirements based on detailed testing. Reprocuring all of the legacy contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. As such, the Organization still has active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Effect or Potential Effect The Organization could potentially be under contract with vendors that are not the best value, not adequately qualified, potentially suspended or debarred, or otherwise not suitable for contract under federal procurement guidelines. No questioned costs were identified, as services/goods under these contracts that were previously tested were deemed to be allowable under the program, and no exceptions noted for allowable costs/activities for samples that included payment to those vendors in previous years or current year. Recommendation The Organization should continue to review all its “legacy” contracts that were procured under the previous procurement policies to determine if there is proper documentation maintained for compliance with applicable procurement guidelines. This includes systematically re-procuring any current contracts not in compliance as soon as feasible. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.
Repeat finding 2023-001, 2022-001, and 2021-002 FAN 93.676 Unaccompanied Alien Children Program Child Nutrition Cluster Procurement and Suspension & Debarment Type of Finding: Non-Compliance U.S. Department of Health & Human Services U.S Department of Agriculture Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: 1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. 3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.” The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. The requirements for non-procurement suspension and debarment are contained in OMB guidance in 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension;” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition The Organization had no findings for contracts procured during the last three fiscal years that were detail tested. However, the Organization’s management recognizes that there are still active contracts under the federal programs for fiscal year ending August 31, 2024 that were procured over three fiscal years ago in which adherence to procurement policies, specifically documentation history of procurement, has not been maintained. In regards to progress made in reducing the number of vendors that are out of compliance, specifically vendors with over $50,000 of annual expenditures that were categorized as “legacy” vendors procured under the previous procurement policies, the Organization went from having 100 vendors totaling approximately $159 million in expenditures as of August 31, 2023, to 46 vendors totaling approximately $119 million as of August 31, 2024. This shows a decrease of 54% in the number of legacy vendors with a decrease of 25% in the dollar-value of the legacy vendors year over year. Further, the Organization continues to make progress in reducing legacy vendor non-compliance by reducing that number to 33 vendors totaling approximately $113 million as of January 2, 2025. As this has been a recurring finding in which management is actively getting all active contracts under the current procurement policies, only those current contracts that were procured in the last three fiscal years were detail tested. Of the approximately 70 active vendor contracts that were procured in the last three fiscal years that were wholly or partially funded with Unaccompanied Alien Children Program revenue dollars or with Child Nutrition Cluster Program revenue dollars, ten were tested with no errors noted. Cause The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Contracts procured within the last three years show compliance with federal requirements based on detailed testing. Reprocuring all of the legacy contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. As such, the Organization still has active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Effect or Potential Effect The Organization could potentially be under contract with vendors that are not the best value, not adequately qualified, potentially suspended or debarred, or otherwise not suitable for contract under federal procurement guidelines. No questioned costs were identified, as services/goods under these contracts that were previously tested were deemed to be allowable under the program, and no exceptions noted for allowable costs/activities for samples that included payment to those vendors in previous years or current year. Recommendation The Organization should continue to review all its “legacy” contracts that were procured under the previous procurement policies to determine if there is proper documentation maintained for compliance with applicable procurement guidelines. This includes systematically re-procuring any current contracts not in compliance as soon as feasible. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.
Repeat finding 2023-001, 2022-001, and 2021-002 FAN 93.676 Unaccompanied Alien Children Program Child Nutrition Cluster Procurement and Suspension & Debarment Type of Finding: Non-Compliance U.S. Department of Health & Human Services U.S Department of Agriculture Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: 1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. 3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.” The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. The requirements for non-procurement suspension and debarment are contained in OMB guidance in 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension;” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition The Organization had no findings for contracts procured during the last three fiscal years that were detail tested. However, the Organization’s management recognizes that there are still active contracts under the federal programs for fiscal year ending August 31, 2024 that were procured over three fiscal years ago in which adherence to procurement policies, specifically documentation history of procurement, has not been maintained. In regards to progress made in reducing the number of vendors that are out of compliance, specifically vendors with over $50,000 of annual expenditures that were categorized as “legacy” vendors procured under the previous procurement policies, the Organization went from having 100 vendors totaling approximately $159 million in expenditures as of August 31, 2023, to 46 vendors totaling approximately $119 million as of August 31, 2024. This shows a decrease of 54% in the number of legacy vendors with a decrease of 25% in the dollar-value of the legacy vendors year over year. Further, the Organization continues to make progress in reducing legacy vendor non-compliance by reducing that number to 33 vendors totaling approximately $113 million as of January 2, 2025. As this has been a recurring finding in which management is actively getting all active contracts under the current procurement policies, only those current contracts that were procured in the last three fiscal years were detail tested. Of the approximately 70 active vendor contracts that were procured in the last three fiscal years that were wholly or partially funded with Unaccompanied Alien Children Program revenue dollars or with Child Nutrition Cluster Program revenue dollars, ten were tested with no errors noted. Cause The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Contracts procured within the last three years show compliance with federal requirements based on detailed testing. Reprocuring all of the legacy contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. As such, the Organization still has active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Effect or Potential Effect The Organization could potentially be under contract with vendors that are not the best value, not adequately qualified, potentially suspended or debarred, or otherwise not suitable for contract under federal procurement guidelines. No questioned costs were identified, as services/goods under these contracts that were previously tested were deemed to be allowable under the program, and no exceptions noted for allowable costs/activities for samples that included payment to those vendors in previous years or current year. Recommendation The Organization should continue to review all its “legacy” contracts that were procured under the previous procurement policies to determine if there is proper documentation maintained for compliance with applicable procurement guidelines. This includes systematically re-procuring any current contracts not in compliance as soon as feasible. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.
Finding Reference: 2024-002 – Procurement Policies and Procedures Federal Agency: U.S Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities - ALN# 10.760 Compliance Requirement: Procurement, suspension, and debarment Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The Authority does not have any documented procurement procedures. However, during our testing of compliance with procurement guidelines, no further deviations from federal guidelines were noted. This is a repeat finding finding from the prior year. Cause and Effect: The Authority was unacquainted with general procurement standards of the Uniform Grant Guidance. Without documented procurement procedures, it is difficult for the Authority to ensure compliance with relevant compliance requirements. Questioned Cost: None Recommendation: The Authority should establish documented procedures related to federal procurement. Views of Responsible Officials: The federal project that has been in the works for multiple years, and, as a result, the Authority determined established procurement procedures would not be written and approved. The Authority did not make this decision in haste. The Authority met compliance guidelines for the procedures of items during the project. What we lack is an approved written document, which at this time is something we do not have the resources to undertake.
2024-005 Full and Open Competition Compliance Requirement Procurement Finding Type Material Weakness in Internal Controls and Material Noncompliance Federal Agency US Department of Education ALN 84.425F and 84.425L Federal Program COVID-19 - Education Stabilization Fund Criteria Entities receiving federal awards are required to conduct procurements in a way that ensures full and open competition. This includes obtaining price or quotes from a sufficient number of qualified sources for purchases exceeding simplified acquisition thresholds, unless a sole-source method is properly justified. All procurement decisions, particularly those involving non-competitive awards, must be supported by appropriate documentation. 2 CFR § 200.319, Competition All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320. 2 CFR § 200.320, Procurement Methods c) Noncompetitive procurement. There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies: The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); The procurement transaction can only be fulfilled by a single source; The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation; The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or After soliciting several sources, competition is determined inadequate. Condition From a sample of twenty-five disbursements selected to test the procurement, we identified four instances where the University utilized sole-source providers for certain purchases. This is permitted under 2 CFR 200.320, provided that proper documentation is maintained. However, the rationale provided was often unclear and did not sufficiently explain why alternative vendors were not considered. Consequently, it was impracticable to determine whether the procurement process fully adhered to competitive standards. To comply with 2 CFR 200.320, future justifications should clearly state the unique nature of the source, any urgent circumstances, specific authorizations, and efforts to solicit competition. Cause The rationale provided in the Sole Provider Justification forms was often unclear and did not sufficiently explain why alternative vendors were not considered. This lack of clarity and detail in the documentation led to uncertainty about whether the procurement process fully adhered to competitive standards. Specifically, the justifications did not adequately address the unique nature of the source, any urgent circumstances, specific authorizations, or efforts to solicit competition, as required by federal regulations. Effect Noncompliance with 2 CFR 200.319, which mandates full and open competition in procurement transactions, and with 2 CFR 200.320 due to improper documentation of sole-source providers, can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs $434,785. These costs were identified due to the failure to adhere to competitive procurement processes and proper documentation requirements for sole-source justifications. Recommendation We recommend the University's management to include in its Sole Provider Justification forms the criterias specified in 2 CFR 200.320. Future justifications should clearly state that the item or service is only available from one source, describe any urgent circumstances that necessitate immediate procurement, reference any specific authorization from the awarding agency, and detail efforts made to solicit competition and why they were unsuccessful. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-005 Full and Open Competition Compliance Requirement Procurement Finding Type Material Weakness in Internal Controls and Material Noncompliance Federal Agency US Department of Education ALN 84.425F and 84.425L Federal Program COVID-19 - Education Stabilization Fund Criteria Entities receiving federal awards are required to conduct procurements in a way that ensures full and open competition. This includes obtaining price or quotes from a sufficient number of qualified sources for purchases exceeding simplified acquisition thresholds, unless a sole-source method is properly justified. All procurement decisions, particularly those involving non-competitive awards, must be supported by appropriate documentation. 2 CFR § 200.319, Competition All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320. 2 CFR § 200.320, Procurement Methods c) Noncompetitive procurement. There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies: The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); The procurement transaction can only be fulfilled by a single source; The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation; The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or After soliciting several sources, competition is determined inadequate. Condition From a sample of twenty-five disbursements selected to test the procurement, we identified four instances where the University utilized sole-source providers for certain purchases. This is permitted under 2 CFR 200.320, provided that proper documentation is maintained. However, the rationale provided was often unclear and did not sufficiently explain why alternative vendors were not considered. Consequently, it was impracticable to determine whether the procurement process fully adhered to competitive standards. To comply with 2 CFR 200.320, future justifications should clearly state the unique nature of the source, any urgent circumstances, specific authorizations, and efforts to solicit competition. Cause The rationale provided in the Sole Provider Justification forms was often unclear and did not sufficiently explain why alternative vendors were not considered. This lack of clarity and detail in the documentation led to uncertainty about whether the procurement process fully adhered to competitive standards. Specifically, the justifications did not adequately address the unique nature of the source, any urgent circumstances, specific authorizations, or efforts to solicit competition, as required by federal regulations. Effect Noncompliance with 2 CFR 200.319, which mandates full and open competition in procurement transactions, and with 2 CFR 200.320 due to improper documentation of sole-source providers, can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs $434,785. These costs were identified due to the failure to adhere to competitive procurement processes and proper documentation requirements for sole-source justifications. Recommendation We recommend the University's management to include in its Sole Provider Justification forms the criterias specified in 2 CFR 200.320. Future justifications should clearly state that the item or service is only available from one source, describe any urgent circumstances that necessitate immediate procurement, reference any specific authorization from the awarding agency, and detail efforts made to solicit competition and why they were unsuccessful. Views of responsible official Refer to Corrective Action Plan (Unaudited)
Finding Reference: 2024-002 – Procurement Policies and Procedures Federal Agency: U.S Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities - ALN# 10.760 Compliance Requirement: Procurement, suspension, and debarment Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The Authority does not have any documented procurement procedures. However, during our testing of compliance with procurement guidelines, no further deviations from federal guidelines were noted. This is a repeat finding finding from the prior year. Cause and Effect: The Authority was unacquainted with general procurement standards of the Uniform Grant Guidance. Without documented procurement procedures, it is difficult for the Authority to ensure compliance with relevant compliance requirements. Questioned Cost: None Recommendation: The Authority should establish documented procedures related to federal procurement. Views of Responsible Officials: The federal project that has been in the works for multiple years, and, as a result, the Authority determined established procurement procedures would not be written and approved. The Authority did not make this decision in haste. The Authority met compliance guidelines for the procedures of items during the project. What we lack is an approved written document, which at this time is something we do not have the resources to undertake.
2024-005 Full and Open Competition Compliance Requirement Procurement Finding Type Material Weakness in Internal Controls and Material Noncompliance Federal Agency US Department of Education ALN 84.425F and 84.425L Federal Program COVID-19 - Education Stabilization Fund Criteria Entities receiving federal awards are required to conduct procurements in a way that ensures full and open competition. This includes obtaining price or quotes from a sufficient number of qualified sources for purchases exceeding simplified acquisition thresholds, unless a sole-source method is properly justified. All procurement decisions, particularly those involving non-competitive awards, must be supported by appropriate documentation. 2 CFR § 200.319, Competition All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320. 2 CFR § 200.320, Procurement Methods c) Noncompetitive procurement. There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies: The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); The procurement transaction can only be fulfilled by a single source; The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation; The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or After soliciting several sources, competition is determined inadequate. Condition From a sample of twenty-five disbursements selected to test the procurement, we identified four instances where the University utilized sole-source providers for certain purchases. This is permitted under 2 CFR 200.320, provided that proper documentation is maintained. However, the rationale provided was often unclear and did not sufficiently explain why alternative vendors were not considered. Consequently, it was impracticable to determine whether the procurement process fully adhered to competitive standards. To comply with 2 CFR 200.320, future justifications should clearly state the unique nature of the source, any urgent circumstances, specific authorizations, and efforts to solicit competition. Cause The rationale provided in the Sole Provider Justification forms was often unclear and did not sufficiently explain why alternative vendors were not considered. This lack of clarity and detail in the documentation led to uncertainty about whether the procurement process fully adhered to competitive standards. Specifically, the justifications did not adequately address the unique nature of the source, any urgent circumstances, specific authorizations, or efforts to solicit competition, as required by federal regulations. Effect Noncompliance with 2 CFR 200.319, which mandates full and open competition in procurement transactions, and with 2 CFR 200.320 due to improper documentation of sole-source providers, can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs $434,785. These costs were identified due to the failure to adhere to competitive procurement processes and proper documentation requirements for sole-source justifications. Recommendation We recommend the University's management to include in its Sole Provider Justification forms the criterias specified in 2 CFR 200.320. Future justifications should clearly state that the item or service is only available from one source, describe any urgent circumstances that necessitate immediate procurement, reference any specific authorization from the awarding agency, and detail efforts made to solicit competition and why they were unsuccessful. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-005 Full and Open Competition Compliance Requirement Procurement Finding Type Material Weakness in Internal Controls and Material Noncompliance Federal Agency US Department of Education ALN 84.425F and 84.425L Federal Program COVID-19 - Education Stabilization Fund Criteria Entities receiving federal awards are required to conduct procurements in a way that ensures full and open competition. This includes obtaining price or quotes from a sufficient number of qualified sources for purchases exceeding simplified acquisition thresholds, unless a sole-source method is properly justified. All procurement decisions, particularly those involving non-competitive awards, must be supported by appropriate documentation. 2 CFR § 200.319, Competition All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320. 2 CFR § 200.320, Procurement Methods c) Noncompetitive procurement. There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies: The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); The procurement transaction can only be fulfilled by a single source; The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation; The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or After soliciting several sources, competition is determined inadequate. Condition From a sample of twenty-five disbursements selected to test the procurement, we identified four instances where the University utilized sole-source providers for certain purchases. This is permitted under 2 CFR 200.320, provided that proper documentation is maintained. However, the rationale provided was often unclear and did not sufficiently explain why alternative vendors were not considered. Consequently, it was impracticable to determine whether the procurement process fully adhered to competitive standards. To comply with 2 CFR 200.320, future justifications should clearly state the unique nature of the source, any urgent circumstances, specific authorizations, and efforts to solicit competition. Cause The rationale provided in the Sole Provider Justification forms was often unclear and did not sufficiently explain why alternative vendors were not considered. This lack of clarity and detail in the documentation led to uncertainty about whether the procurement process fully adhered to competitive standards. Specifically, the justifications did not adequately address the unique nature of the source, any urgent circumstances, specific authorizations, or efforts to solicit competition, as required by federal regulations. Effect Noncompliance with 2 CFR 200.319, which mandates full and open competition in procurement transactions, and with 2 CFR 200.320 due to improper documentation of sole-source providers, can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs $434,785. These costs were identified due to the failure to adhere to competitive procurement processes and proper documentation requirements for sole-source justifications. Recommendation We recommend the University's management to include in its Sole Provider Justification forms the criterias specified in 2 CFR 200.320. Future justifications should clearly state that the item or service is only available from one source, describe any urgent circumstances that necessitate immediate procurement, reference any specific authorization from the awarding agency, and detail efforts made to solicit competition and why they were unsuccessful. Views of responsible official Refer to Corrective Action Plan (Unaudited)
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). 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. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). 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. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). 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. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). 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. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). 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. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). 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. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). 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. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Finding 2024-004 Type of Finding: Significant deficiency in internal controls over compliance and immaterial noncompliance. Federal Award Program: HUD Supportive Housing for Persons with Disabilities (Assistance Listing #14.181) Compliance Requirement: Procurement Criteria: Pursuant to the Uniform Guidance, for procurements of goods and services made with federal awards, River Kourt Apartments is required to have policies in place that conform with the Procurement Standards as prescribed in 2 CFR §200.318 through §200.320. River Kourt Apartments is required to follow the methods of procurement as prescribed in 2 CFR §200.320. Condition: River Kourt Apartments has written policies and procedures regarding the procurement of goods and services; however, the written procedures did not include all required elements regarding procurement procedures pursuant to 2 CFR §200.318 through §200.320. Cause: River Kourt Apartments has written policies and procedures regarding the procurement of goods and services; however, the written procedures did not include all required elements regarding procurement procedures pursuant to 2 CFR §200.318 through §200.320. Effect of Condition: This increases risk that River Kourt Apartments would not materially comply with the procurement requirement for the major program. Questioned Costs: None. Context: There were no procurements over the de minimis threshold made during the year period ended June 30, 2024; however, the written procedures did not include all required elements regarding procurement procedures pursuant to 2 CFR §200.318 through §200.320. Repeat Finding: Yes, see Finding 2023-003. Recommendation: We recommend management revise the current policies and procedures to include all required elements for procurement procedures pursuant to 2 CFR §200.318 through §200.320. Procurement methods shall follow the methods as prescribed in 2 CFR §200.320. View of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, 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. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Assistance Listing # 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Fiscal year finding initially occurred: 2024 Criteria In accordance with 2 CFR 200.320, the City of Scott is required to formally bid contracts that exceed $250,000. Condition The City expended $261,009 of Coronavirus State and Local Fiscal Recovery Funds on a contract that exceeded the required threshold but was not formally bid. Cause The City expended federal funds on contracts that were not properly bid by federal guidelines. Effect As a result, the City was not in compliance with procurement requirements with questioned costs totaling $261,009. Context A sample of 19 transactions were selected for audit from a population of 29 disbursements. The test found that a vendor was not properly contracted. This resulted in questioned costs of $261,009. Recommendation The City should review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320. Management’s Corrective Action Plan The City of Scott will review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320.
Assistance Listing # 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Fiscal year finding initially occurred: 2024 Criteria In accordance with 2 CFR 200.320, the City of Scott is required to formally bid contracts that exceed $250,000. Condition The City expended $261,009 of Coronavirus State and Local Fiscal Recovery Funds on a contract that exceeded the required threshold but was not formally bid. Cause The City expended federal funds on contracts that were not properly bid by federal guidelines. Effect As a result, the City was not in compliance with procurement requirements with questioned costs totaling $261,009. Context A sample of 19 transactions were selected for audit from a population of 29 disbursements. The test found that a vendor was not properly contracted. This resulted in questioned costs of $261,009. Recommendation The City should review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320. Management’s Corrective Action Plan The City of Scott will review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320.
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Elementary and Secondary School Emergency Relief Federal Award Identification Number: S425U210026 Pass-Through Agency: Kentucky Department of Education Pass-Through Entity Identifying Numbers: 473G Assistance Listing Number: 84.425 Award Period: March 24, 2021 to September 30, 2024 Condition: We noted that proper bid procedures were not followed for a flooring replacement project that was completed during the year and whose total cost exceeded $40,000. Criteria: State and federal regulations (KRS 424.260 and 2 CFR 200.320) and Board policy requires that all like items purchased during the fiscal year exceeding $40,000 be purchased through a competitive bidding process or at state/federal contract pricing. Repeat Finding: No. Questioned Costs: $79,620 Effect: Noncompliance with KRS 424.260, 2 CFR 200.320 and Board policy. Recommendation: We recommend that the District implement procedures to ensure compliance with state and federal regulations and Board policy.
Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Elementary and Secondary School Emergency Relief Federal Award Identification Number: S425U210026 Pass-Through Agency: Kentucky Department of Education Pass-Through Entity Identifying Numbers: 473G Assistance Listing Number: 84.425 Award Period: March 24, 2021 to September 30, 2024 Condition: We noted that proper bid procedures were not followed for a flooring replacement project that was completed during the year and whose total cost exceeded $40,000. Criteria: State and federal regulations (KRS 424.260 and 2 CFR 200.320) and Board policy requires that all like items purchased during the fiscal year exceeding $40,000 be purchased through a competitive bidding process or at state/federal contract pricing. Repeat Finding: No. Questioned Costs: $79,620 Effect: Noncompliance with KRS 424.260, 2 CFR 200.320 and Board policy. Recommendation: We recommend that the District implement procedures to ensure compliance with state and federal regulations and Board policy.