Department of Health and Human Services Federal Financial Assistance Listing 93.591, 2201SDSDVC, 2301SDSDVC, 2101SDSDC6, 2201SDSTC6 Family Violence Prevention and Services/State Domestic Violence Coalitions Procurement, Suspension, & Debarment Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must create and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, 2 CFR 200.320 notes for any of the procurement methods described in the section, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the standards of the section. Condition: There were two instances where the review and approval process did not identify the correct procurement method on the procurement worksheet. The correct method was used, however was not properly documented on the Organization's internal worksheet. In addition, the contracts tested did not include some of the required provisions. Cause: The Organization’s review process did not identify the errors. Effect: Without following the established procurement procedures, it is difficult to demonstrate compliance with the federal requirements. Questioned Costs: None reported Context/Sampling: There were two contracts entered into during the current year and both were tested. Repeat Finding from Prior Year(s): No Recommendation: We recommend that management review the procurement procedures with applicable employees to ensure procedures are followed going forward. In addition, we suggest management review the contract process to ensure that contracts contain all required contract provisions. Views of Responsible Officials: Management is in agreement.
Department of Health and Human Services Federal Financial Assistance Listing 93.591, 2201SDSDVC, 2301SDSDVC, 2101SDSDC6, 2201SDSTC6 Family Violence Prevention and Services/State Domestic Violence Coalitions Procurement, Suspension, & Debarment Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must create and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, 2 CFR 200.320 notes for any of the procurement methods described in the section, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the standards of the section. Condition: There were two instances where the review and approval process did not identify the correct procurement method on the procurement worksheet. The correct method was used, however was not properly documented on the Organization's internal worksheet. In addition, the contracts tested did not include some of the required provisions. Cause: The Organization’s review process did not identify the errors. Effect: Without following the established procurement procedures, it is difficult to demonstrate compliance with the federal requirements. Questioned Costs: None reported Context/Sampling: There were two contracts entered into during the current year and both were tested. Repeat Finding from Prior Year(s): No Recommendation: We recommend that management review the procurement procedures with applicable employees to ensure procedures are followed going forward. In addition, we suggest management review the contract process to ensure that contracts contain all required contract provisions. Views of Responsible Officials: Management is in agreement.
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.
Assistance Listing, Federal Agency, and Program Name - 21.027 - COVID - 19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - SLFRP0126 Pass through Entity - U.S. Department of Treasury Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR 200.320 and 200.324 outlines the auditee responsibility to utilize the appropriate procurement method and comply with all related requirements of that selected procurement methodology. Also, 2 CFR 180.300 outlines the auditee responsibility related to suspension and debarment requirements for vendors with whom an entity contracts. Condition - The School District did not have sufficient controls in place to ensure compliance with its procurement policy and that appropriate documentation is retained regarding the procurement methodology chosen and support for compliance with the suspension and debarment requirements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the sample of 2 contracts procured this year that we selected for testing, 2 did not have the required support for the procurement method selected based on federal guidelines and the School District's procurement policy. Additionally, the 2 contracts selected for suspension and debarment testing did not have any documentation as it related to suspension and debarment. Cause and Effect - The School District did not retain support to show it obtained price quotes, as required by the small purchases provision; had the appropriate rationale, as required by the noncompetitive solicitation provision; or had support for proposals submitted, as required by the purchases over $250,000 provision. Support was not retained for 2 of the 2 samples selected during procurement testing; therefore, procurement methodology was not supported. Additionally, none of the 2 samples selected for suspension and debarment testing had the required support retained. Recommendation - We recommend the School District implement internal control procedures to ensure that procurement policy is followed and the proper documentation is kept in the procurement files to support any and all procurement decisions in accordance with the purchasing policy and federal regulations. Views of Responsible Officials and Planned Corrective Actions - This finding was due to the District having turnover among key personnel in the grants area, as well as non adherence to policies and procedures related to grant records, grant accounting, and year end close processes. The District will work with the Materials and Procurement department to ensure policies and procedures are updated and staff is trained. Prior to awarding any contract, District staff will search the federal Excluded Parties List System to determine that the contractor is not suspended or debarred. Documentation of this search will be maintained in the grant procurement file.
Finding 2024-001 Material Weakness, Compliance and Internal Control Over Procurement, Suspension and Debarment Compliance CFDA 93.676 - Unaccompanied Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Global Refuge and Lutheran Immigration and Refugee Services Criteria Or Specific Requirement: The organization must adhere to the procurement methods outlined in 2 CFR 200.320, using informal procedures for small purchases, formal methods (sealed bids or proposals) for larger ones, or noncompetitive methods as appropriate. The organization is responsible for establishing processes and procedures for each method and maintaining relevant documentation. Additionally, as per 2 CFR 200.213, the organization must not contract with suspended or debarred parties. Before entering into a covered transaction, the organization must verify the eligibility of the potential contractor. Condition: The Organization has not ensured compliance with appropriate procurement methods, retention of necessary documents and decisions, or pre-contractual review for suspension and debarment requirements. Cause: The Organization lacks sufficient policies and controls to ensure compliance with Federal procurement, suspension, and debarment regulations. Effect: The Organization's failure to fully comply with procurement, suspension and debarment requirements could have led to contracts with suspended or debarred parties or contracts awarded through improper methods. Questioned Costs: Not applicable Context: Three of the five contracts reviewed lacked sufficient documentation to support the procurement methodology used. While no payments were made to debarred parties, the absence of a policy or procedure to prevent such occurrences poses a significant risk. Identification As A Repeat Finding: N/A Recommendation: We recommend that Organization implement internal policies to identify appropriate procurement methodologies, conduct regular suspension and debarment checks, maintain adequate file documentation to ensure compliance with procurement and suspension/debarment regulations and prevent contracts with ineligible parties. Views Of Responsible Officials And Planned Corrective Action: The Organization agrees with the finding and has put together a corrective action plan for the finding. See corrective action plan included in this report.
Finding 2024-001 Material Weakness, Compliance and Internal Control Over Procurement, Suspension and Debarment Compliance CFDA 93.676 - Unaccompanied Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Global Refuge and Lutheran Immigration and Refugee Services Criteria Or Specific Requirement: The organization must adhere to the procurement methods outlined in 2 CFR 200.320, using informal procedures for small purchases, formal methods (sealed bids or proposals) for larger ones, or noncompetitive methods as appropriate. The organization is responsible for establishing processes and procedures for each method and maintaining relevant documentation. Additionally, as per 2 CFR 200.213, the organization must not contract with suspended or debarred parties. Before entering into a covered transaction, the organization must verify the eligibility of the potential contractor. Condition: The Organization has not ensured compliance with appropriate procurement methods, retention of necessary documents and decisions, or pre-contractual review for suspension and debarment requirements. Cause: The Organization lacks sufficient policies and controls to ensure compliance with Federal procurement, suspension, and debarment regulations. Effect: The Organization's failure to fully comply with procurement, suspension and debarment requirements could have led to contracts with suspended or debarred parties or contracts awarded through improper methods. Questioned Costs: Not applicable Context: Three of the five contracts reviewed lacked sufficient documentation to support the procurement methodology used. While no payments were made to debarred parties, the absence of a policy or procedure to prevent such occurrences poses a significant risk. Identification As A Repeat Finding: N/A Recommendation: We recommend that Organization implement internal policies to identify appropriate procurement methodologies, conduct regular suspension and debarment checks, maintain adequate file documentation to ensure compliance with procurement and suspension/debarment regulations and prevent contracts with ineligible parties. Views Of Responsible Officials And Planned Corrective Action: The Organization agrees with the finding and has put together a corrective action plan for the finding. See corrective action plan included in this report.
Finding 2024-001 Material Weakness, Compliance and Internal Control Over Procurement, Suspension and Debarment Compliance CFDA 93.676 - Unaccompanied Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Global Refuge and Lutheran Immigration and Refugee Services Criteria Or Specific Requirement: The organization must adhere to the procurement methods outlined in 2 CFR 200.320, using informal procedures for small purchases, formal methods (sealed bids or proposals) for larger ones, or noncompetitive methods as appropriate. The organization is responsible for establishing processes and procedures for each method and maintaining relevant documentation. Additionally, as per 2 CFR 200.213, the organization must not contract with suspended or debarred parties. Before entering into a covered transaction, the organization must verify the eligibility of the potential contractor. Condition: The Organization has not ensured compliance with appropriate procurement methods, retention of necessary documents and decisions, or pre-contractual review for suspension and debarment requirements. Cause: The Organization lacks sufficient policies and controls to ensure compliance with Federal procurement, suspension, and debarment regulations. Effect: The Organization's failure to fully comply with procurement, suspension and debarment requirements could have led to contracts with suspended or debarred parties or contracts awarded through improper methods. Questioned Costs: Not applicable Context: Three of the five contracts reviewed lacked sufficient documentation to support the procurement methodology used. While no payments were made to debarred parties, the absence of a policy or procedure to prevent such occurrences poses a significant risk. Identification As A Repeat Finding: N/A Recommendation: We recommend that Organization implement internal policies to identify appropriate procurement methodologies, conduct regular suspension and debarment checks, maintain adequate file documentation to ensure compliance with procurement and suspension/debarment regulations and prevent contracts with ineligible parties. Views Of Responsible Officials And Planned Corrective Action: The Organization agrees with the finding and has put together a corrective action plan for the finding. See corrective action plan included in this report.
Finding 2024-001 Material Weakness, Compliance and Internal Control Over Procurement, Suspension and Debarment Compliance CFDA 93.676 - Unaccompanied Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Global Refuge and Lutheran Immigration and Refugee Services Criteria Or Specific Requirement: The organization must adhere to the procurement methods outlined in 2 CFR 200.320, using informal procedures for small purchases, formal methods (sealed bids or proposals) for larger ones, or noncompetitive methods as appropriate. The organization is responsible for establishing processes and procedures for each method and maintaining relevant documentation. Additionally, as per 2 CFR 200.213, the organization must not contract with suspended or debarred parties. Before entering into a covered transaction, the organization must verify the eligibility of the potential contractor. Condition: The Organization has not ensured compliance with appropriate procurement methods, retention of necessary documents and decisions, or pre-contractual review for suspension and debarment requirements. Cause: The Organization lacks sufficient policies and controls to ensure compliance with Federal procurement, suspension, and debarment regulations. Effect: The Organization's failure to fully comply with procurement, suspension and debarment requirements could have led to contracts with suspended or debarred parties or contracts awarded through improper methods. Questioned Costs: Not applicable Context: Three of the five contracts reviewed lacked sufficient documentation to support the procurement methodology used. While no payments were made to debarred parties, the absence of a policy or procedure to prevent such occurrences poses a significant risk. Identification As A Repeat Finding: N/A Recommendation: We recommend that Organization implement internal policies to identify appropriate procurement methodologies, conduct regular suspension and debarment checks, maintain adequate file documentation to ensure compliance with procurement and suspension/debarment regulations and prevent contracts with ineligible parties. Views Of Responsible Officials And Planned Corrective Action: The Organization agrees with the finding and has put together a corrective action plan for the finding. See corrective action plan included in this report.
FINDING 2024-002 Information on the federal program: Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement Audit Finding: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For one of the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The sample item amount disbursed was $69,649 in FY23 and $110,313 in FY24 for food service technology support. The School Corporation did properly perform a suspension and debarment check on the vendor. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that the School Corporation’s procurement policy is adhered to and quotes are obtained from an adequate number of qualified sources as required for small purchase method procurements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-002 Information on the federal program: Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement Audit Finding: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For one of the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The sample item amount disbursed was $69,649 in FY23 and $110,313 in FY24 for food service technology support. The School Corporation did properly perform a suspension and debarment check on the vendor. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that the School Corporation’s procurement policy is adhered to and quotes are obtained from an adequate number of qualified sources as required for small purchase method procurements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-002 Information on the federal program: Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement Audit Finding: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For one of the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The sample item amount disbursed was $69,649 in FY23 and $110,313 in FY24 for food service technology support. The School Corporation did properly perform a suspension and debarment check on the vendor. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that the School Corporation’s procurement policy is adhered to and quotes are obtained from an adequate number of qualified sources as required for small purchase method procurements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-002 Information on the federal program: Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement Audit Finding: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For one of the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The sample item amount disbursed was $69,649 in FY23 and $110,313 in FY24 for food service technology support. The School Corporation did properly perform a suspension and debarment check on the vendor. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that the School Corporation’s procurement policy is adhered to and quotes are obtained from an adequate number of qualified sources as required for small purchase method procurements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
2024-005 Procurement, Suspension & Debarment – Child Nutrition Cluster Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Award Period: July 1, 2023 – June 30, 2024 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment. Questioned Costs: None Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2024-005 Procurement, Suspension & Debarment – Child Nutrition Cluster (Continued) Repeat Finding: Repeat finding 2023-005. Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
2024-005 Procurement, Suspension & Debarment – Child Nutrition Cluster Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Award Period: July 1, 2023 – June 30, 2024 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment. Questioned Costs: None Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2024-005 Procurement, Suspension & Debarment – Child Nutrition Cluster (Continued) Repeat Finding: Repeat finding 2023-005. Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
2024-005 Procurement, Suspension & Debarment – Child Nutrition Cluster Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Award Period: July 1, 2023 – June 30, 2024 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment. Questioned Costs: None Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2024-005 Procurement, Suspension & Debarment – Child Nutrition Cluster (Continued) Repeat Finding: Repeat finding 2023-005. Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
2024-005 Procurement, Suspension & Debarment – Child Nutrition Cluster Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Award Period: July 1, 2023 – June 30, 2024 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment. Questioned Costs: None Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2024-005 Procurement, Suspension & Debarment – Child Nutrition Cluster (Continued) Repeat Finding: Repeat finding 2023-005. Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
2024-005 Procurement, Suspension & Debarment – Child Nutrition Cluster Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Award Period: July 1, 2023 – June 30, 2024 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment. Questioned Costs: None Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2024-005 Procurement, Suspension & Debarment – Child Nutrition Cluster (Continued) Repeat Finding: Repeat finding 2023-005. Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
Federal Agencies: Department of Housing and Urban Development Federal Program Names: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL0395L5T102113,IL0395L5T102214, IL0232L5T102215, IL0184L5T102215, IL0184L5T102316, IL1790H5T102200, IL1791H5T102200, IL1792H5T102200,197661, IL1759D5T102100, 8567-C, 8567-D Award Period: 9/1/2022-8/31/2023; 9/1/2023-8/31/2024; 7/1/2023-6/30/2024; 3/1/2023-2/29/2024; 3/1/2024-5/31/2025; 9/1/2023-8/31/2026; 10/1/2022-9/30/2023; 10/1/2023-6/30/2024; 2/1/2024-4/30/2024; 5/1/2024-4/30/2025 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Inner Voice did not maintain appropriate documentation to support the procurement method utilized for procurement selected for testing. Questioned Costs: Unknown. Context: One (1) of five (5) procurement transactions selected for testing. Cause: Inner Voice did not maintain appropriate documentation based on the method of procurement utilized. Effect: Inner Voice may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend Inner Voice to consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with this finding.
FINDING 2024-004: PROCUREMENT (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, requires the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “formal purchases,” those where the aggregate dollar amount is higher than the simplified acquisition threshold, sealed bids are publicly solicited through an invitation and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid conforms with all the material terms and conditions of the invitation and is the lowest in price. Condition: During our testing we discovered one contract which lacked documentation to demonstrate that competitive bids were obtained, contractor selection or rejection, and determination as to whom the contract was awarded to. Context: Error was isolated to one contract tested. Questioned Costs: This resulted in a contract of $997,040 being awarded without competitive bidding documentation. Cause: Change in key management. Effect: The District could potentially award contracts without doing due diligence. Recommendation: We recommend that the District comply with 2 CFR, section 200.318-322, which requires that an LEA maintain the documented procedures for procurement transactions under a federal award. Views of Responsible Officials: We posted a job walk and had one bidder. In the future we will post for a longer period of time and if needed repost for a second job walk. We will note each company that attends and if they did or did not chose to bid the job. The documentation of each bid and the board approval for the awarded bid will now be maintained at both the Construction, Maintenance, and Operations Department and the District Office to lessen the loss of documentation due to employee turnover.
FINDING 2024-004: PROCUREMENT (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, requires the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “formal purchases,” those where the aggregate dollar amount is higher than the simplified acquisition threshold, sealed bids are publicly solicited through an invitation and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid conforms with all the material terms and conditions of the invitation and is the lowest in price. Condition: During our testing we discovered one contract which lacked documentation to demonstrate that competitive bids were obtained, contractor selection or rejection, and determination as to whom the contract was awarded to. Context: Error was isolated to one contract tested. Questioned Costs: This resulted in a contract of $997,040 being awarded without competitive bidding documentation. Cause: Change in key management. Effect: The District could potentially award contracts without doing due diligence. Recommendation: We recommend that the District comply with 2 CFR, section 200.318-322, which requires that an LEA maintain the documented procedures for procurement transactions under a federal award. Views of Responsible Officials: We posted a job walk and had one bidder. In the future we will post for a longer period of time and if needed repost for a second job walk. We will note each company that attends and if they did or did not chose to bid the job. The documentation of each bid and the board approval for the awarded bid will now be maintained at both the Construction, Maintenance, and Operations Department and the District Office to lessen the loss of documentation due to employee turnover.
FINDING 2024-004: PROCUREMENT (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, requires the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “formal purchases,” those where the aggregate dollar amount is higher than the simplified acquisition threshold, sealed bids are publicly solicited through an invitation and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid conforms with all the material terms and conditions of the invitation and is the lowest in price. Condition: During our testing we discovered one contract which lacked documentation to demonstrate that competitive bids were obtained, contractor selection or rejection, and determination as to whom the contract was awarded to. Context: Error was isolated to one contract tested. Questioned Costs: This resulted in a contract of $997,040 being awarded without competitive bidding documentation. Cause: Change in key management. Effect: The District could potentially award contracts without doing due diligence. Recommendation: We recommend that the District comply with 2 CFR, section 200.318-322, which requires that an LEA maintain the documented procedures for procurement transactions under a federal award. Views of Responsible Officials: We posted a job walk and had one bidder. In the future we will post for a longer period of time and if needed repost for a second job walk. We will note each company that attends and if they did or did not chose to bid the job. The documentation of each bid and the board approval for the awarded bid will now be maintained at both the Construction, Maintenance, and Operations Department and the District Office to lessen the loss of documentation due to employee turnover.
FINDING 2024-004: PROCUREMENT (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, requires the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “formal purchases,” those where the aggregate dollar amount is higher than the simplified acquisition threshold, sealed bids are publicly solicited through an invitation and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid conforms with all the material terms and conditions of the invitation and is the lowest in price. Condition: During our testing we discovered one contract which lacked documentation to demonstrate that competitive bids were obtained, contractor selection or rejection, and determination as to whom the contract was awarded to. Context: Error was isolated to one contract tested. Questioned Costs: This resulted in a contract of $997,040 being awarded without competitive bidding documentation. Cause: Change in key management. Effect: The District could potentially award contracts without doing due diligence. Recommendation: We recommend that the District comply with 2 CFR, section 200.318-322, which requires that an LEA maintain the documented procedures for procurement transactions under a federal award. Views of Responsible Officials: We posted a job walk and had one bidder. In the future we will post for a longer period of time and if needed repost for a second job walk. We will note each company that attends and if they did or did not chose to bid the job. The documentation of each bid and the board approval for the awarded bid will now be maintained at both the Construction, Maintenance, and Operations Department and the District Office to lessen the loss of documentation due to employee turnover.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Identification Number and Year: None Provided Pass-Through Agency: Maryland Department of Education (MSDE) Pass-Through Number(s): None Provided Award Period: 7/1/2023–6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: 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 200.327. 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. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do 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 (2 CFR section 200.320(b)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: During the testing of ten contracts, the Board was unable to provide documentation for one contract to demonstrate compliance with their procurement policy, specifically the requirement to obtain two quotes for a small purchase. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that the Board’s procurement policies were followed for contracts entered into where expenses were charged to the federal program. Effect: There is an increased risk of charging unallowed costs to the program. Repeat Finding: No. Recommendation: We recommend that the Board enhance controls and procedures to ensure that it follows its procurement policies for all goods and services charged to the program. Documentation should be readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Identification Number and Year: None Provided Pass-Through Agency: Maryland Department of Education (MSDE) Pass-Through Number(s): None Provided Award Period: 7/1/2023–6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: 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 200.327. 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. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do 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 (2 CFR section 200.320(b)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: During the testing of ten contracts, the Board was unable to provide documentation for one contract to demonstrate compliance with their procurement policy, specifically the requirement to obtain two quotes for a small purchase. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that the Board’s procurement policies were followed for contracts entered into where expenses were charged to the federal program. Effect: There is an increased risk of charging unallowed costs to the program. Repeat Finding: No. Recommendation: We recommend that the Board enhance controls and procedures to ensure that it follows its procurement policies for all goods and services charged to the program. Documentation should be readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Identification Number and Year: None Provided Pass-Through Agency: Maryland Department of Education (MSDE) Pass-Through Number(s): None Provided Award Period: 7/1/2023–6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: 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 200.327. 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. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do 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 (2 CFR section 200.320(b)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: During the testing of ten contracts, the Board was unable to provide documentation for one contract to demonstrate compliance with their procurement policy, specifically the requirement to obtain two quotes for a small purchase. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that the Board’s procurement policies were followed for contracts entered into where expenses were charged to the federal program. Effect: There is an increased risk of charging unallowed costs to the program. Repeat Finding: No. Recommendation: We recommend that the Board enhance controls and procedures to ensure that it follows its procurement policies for all goods and services charged to the program. Documentation should be readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Identification Number and Year: None Provided Pass-Through Agency: Maryland Department of Education (MSDE) Pass-Through Number(s): None Provided Award Period: 7/1/2023–6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: 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 200.327. 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. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do 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 (2 CFR section 200.320(b)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: During the testing of ten contracts, the Board was unable to provide documentation for one contract to demonstrate compliance with their procurement policy, specifically the requirement to obtain two quotes for a small purchase. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that the Board’s procurement policies were followed for contracts entered into where expenses were charged to the federal program. Effect: There is an increased risk of charging unallowed costs to the program. Repeat Finding: No. Recommendation: We recommend that the Board enhance controls and procedures to ensure that it follows its procurement policies for all goods and services charged to the program. Documentation should be readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Identification Number and Year: None Provided Pass-Through Agency: Maryland Department of Education (MSDE) Pass-Through Number(s): None Provided Award Period: 7/1/2023–6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: 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 200.327. 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. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do 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 (2 CFR section 200.320(b)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: During the testing of ten contracts, the Board was unable to provide documentation for one contract to demonstrate compliance with their procurement policy, specifically the requirement to obtain two quotes for a small purchase. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that the Board’s procurement policies were followed for contracts entered into where expenses were charged to the federal program. Effect: There is an increased risk of charging unallowed costs to the program. Repeat Finding: No. Recommendation: We recommend that the Board enhance controls and procedures to ensure that it follows its procurement policies for all goods and services charged to the program. Documentation should be readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Identification Number and Year: None Provided Pass-Through Agency: Maryland Department of Education (MSDE) Pass-Through Number(s): None Provided Award Period: 7/1/2023–6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: 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 200.327. 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. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do 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 (2 CFR section 200.320(b)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: During the testing of ten contracts, the Board was unable to provide documentation for one contract to demonstrate compliance with their procurement policy, specifically the requirement to obtain two quotes for a small purchase. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that the Board’s procurement policies were followed for contracts entered into where expenses were charged to the federal program. Effect: There is an increased risk of charging unallowed costs to the program. Repeat Finding: No. Recommendation: We recommend that the Board enhance controls and procedures to ensure that it follows its procurement policies for all goods and services charged to the program. Documentation should be readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Identification Number and Year: None Provided Pass-Through Agency: Maryland Department of Education (MSDE) Pass-Through Number(s): None Provided Award Period: 7/1/2023–6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: 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 200.327. 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. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do 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 (2 CFR section 200.320(b)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: During the testing of ten contracts, the Board was unable to provide documentation for one contract to demonstrate compliance with their procurement policy, specifically the requirement to obtain two quotes for a small purchase. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that the Board’s procurement policies were followed for contracts entered into where expenses were charged to the federal program. Effect: There is an increased risk of charging unallowed costs to the program. Repeat Finding: No. Recommendation: We recommend that the Board enhance controls and procedures to ensure that it follows its procurement policies for all goods and services charged to the program. Documentation should be readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.
21.027 – Coronavirus State and Local Fiscal Recovery Funds Noncompliance with Procurement, Suspension and Debarment and Material Weakness in Internal Controls Criteria: 2 CFR Part 200.320(b) indicates “Formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient.” Condition: During the fiscal year, the County Fair entered into a contract which exceeded the County’s simplified acquisition threshold of $250,000 but did not use formal procurement methods. Cause: The County Fair did not obtain sealed bids or proposals. Effect: By not following formal procurement methods, the County may pay more for goods and services than is necessary. Questioned Costs: $285,543 Recommendations: The County should establish and follow procurement policies and procedures to ensure the County as a whole adheres to requirements established by the Federal Government. Views of Responsible Officials: Hood River County will be working with the County Fair Board in the coming fiscal year to make corrections. The U.S. government requires recipients of federal grants, such as Hood River County, to adhere to specific terms and conditions. The overarching requirement Hood River County must follow is the Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, referred to as Uniform Guidance. Hood River County is training personnel to be mindful of following this guidance when making purchases.
21.027 – Coronavirus State and Local Fiscal Recovery Funds Noncompliance with Procurement, Suspension and Debarment and Material Weakness in Internal Controls Criteria: 2 CFR Part 200.320(b) indicates “Formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient.” Condition: During the fiscal year, the County Fair entered into a contract which exceeded the County’s simplified acquisition threshold of $250,000 but did not use formal procurement methods. Cause: The County Fair did not obtain sealed bids or proposals. Effect: By not following formal procurement methods, the County may pay more for goods and services than is necessary. Questioned Costs: $285,543 Recommendations: The County should establish and follow procurement policies and procedures to ensure the County as a whole adheres to requirements established by the Federal Government. Views of Responsible Officials: Hood River County will be working with the County Fair Board in the coming fiscal year to make corrections. The U.S. government requires recipients of federal grants, such as Hood River County, to adhere to specific terms and conditions. The overarching requirement Hood River County must follow is the Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, referred to as Uniform Guidance. Hood River County is training personnel to be mindful of following this guidance when making purchases.
21.027 – Coronavirus State and Local Fiscal Recovery Funds Noncompliance with Procurement, Suspension and Debarment and Material Weakness in Internal Controls Criteria: 2 CFR Part 200.320(b) indicates “Formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient.” Condition: During the fiscal year, the County Fair entered into a contract which exceeded the County’s simplified acquisition threshold of $250,000 but did not use formal procurement methods. Cause: The County Fair did not obtain sealed bids or proposals. Effect: By not following formal procurement methods, the County may pay more for goods and services than is necessary. Questioned Costs: $285,543 Recommendations: The County should establish and follow procurement policies and procedures to ensure the County as a whole adheres to requirements established by the Federal Government. Views of Responsible Officials: Hood River County will be working with the County Fair Board in the coming fiscal year to make corrections. The U.S. government requires recipients of federal grants, such as Hood River County, to adhere to specific terms and conditions. The overarching requirement Hood River County must follow is the Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, referred to as Uniform Guidance. Hood River County is training personnel to be mindful of following this guidance when making purchases.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.