FA 2024-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Numbers: 245GA324N1199 (Year: 2024), 235GA32N1099 (Year: 2023) Questioned Costs: $7,388 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District’s procurement and suspension and debarment procedures were followed. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $1,087,437.24 were expended and reported on the Wilkinson County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Condition: A sample of 39 expenditures was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. For eight of the 10 sample expenditures that were incurred outside of the School District’s Co-Op process, evidence of review and approval was not reflected within the voucher package. Additionally, auditor reviewed five of these same expenditures and a sample of 29 additional expenditures, which was randomly selected for testing using a non-statistical sampling approach, to determine if procurement transactions complied with the School District’s procurement procedures and proper oversight was maintained to ensure that contractors were performing according to their contracts. The following deficiencies were noted with expenditures incurred outside of the School District’s Co-Op process: • Evidence of review and approval was not reflected within the voucher package and/or purchase files for 17 additional expenditures. • The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for eight small purchase expenditures reviewed. Questioned Costs: Upon testing a sample of $14,237 in procurement transactions that were incurred outside of the School District’s Co-Op process, known questioned costs of $7,388 were identified for expenditures that did not follow the School District’s procurement procedures. Using the population of procurements that were incurred outside of the School District’s Co-Op process of $56,274, we project the likely questioned costs to be approximately $29,200. Cause: The School District did not follow its policies and procedures that govern the nonpersonal services expenditure process for federal programs. Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance related to CNC. Failure to ensure that expenditures are appropriately approved and procedures to address procurement and suspension and debarment compliance requirements are implemented exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds for unallowable purposes and/or with unqualified vendors. In addition, this deficiency could lead to the return of funding associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to CNC. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all expenditures reflect evidence of review and approval, required procurement methods are properly identified and followed and required procurement and suspension and debarment documentation is properly identified, safeguarded, and retained. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.
FA 2024-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Numbers: 245GA324N1199 (Year: 2024), 235GA32N1099 (Year: 2023) Questioned Costs: $7,388 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District’s procurement and suspension and debarment procedures were followed. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $1,087,437.24 were expended and reported on the Wilkinson County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Condition: A sample of 39 expenditures was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. For eight of the 10 sample expenditures that were incurred outside of the School District’s Co-Op process, evidence of review and approval was not reflected within the voucher package. Additionally, auditor reviewed five of these same expenditures and a sample of 29 additional expenditures, which was randomly selected for testing using a non-statistical sampling approach, to determine if procurement transactions complied with the School District’s procurement procedures and proper oversight was maintained to ensure that contractors were performing according to their contracts. The following deficiencies were noted with expenditures incurred outside of the School District’s Co-Op process: • Evidence of review and approval was not reflected within the voucher package and/or purchase files for 17 additional expenditures. • The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for eight small purchase expenditures reviewed. Questioned Costs: Upon testing a sample of $14,237 in procurement transactions that were incurred outside of the School District’s Co-Op process, known questioned costs of $7,388 were identified for expenditures that did not follow the School District’s procurement procedures. Using the population of procurements that were incurred outside of the School District’s Co-Op process of $56,274, we project the likely questioned costs to be approximately $29,200. Cause: The School District did not follow its policies and procedures that govern the nonpersonal services expenditure process for federal programs. Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance related to CNC. Failure to ensure that expenditures are appropriately approved and procedures to address procurement and suspension and debarment compliance requirements are implemented exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds for unallowable purposes and/or with unqualified vendors. In addition, this deficiency could lead to the return of funding associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to CNC. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all expenditures reflect evidence of review and approval, required procurement methods are properly identified and followed and required procurement and suspension and debarment documentation is properly identified, safeguarded, and retained. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Per section 200.320 in Subpart D of the code of federal regulations (CFR) the non-federal entity is responsible for complying with small purchase procedures for procurement. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($50,000) but does not exceed the simplified acquisition threshold ($250,000). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines.No reportable questioned costs were identified. The District's Board policy for procurement for small purchase procedures states that if small purchase procedures are used that the District obtain price or rate quotations from and adequate number of qualified sources as determined by the District. During our audit procedures we were unable to obtain supporting documentation for multiple price or rate quotations for the goods procured from the food service vendor during the year. The District did not follow appropriate procurement policy procedures for purchases made under the small purchase procedures within the food service program. The District did not obtain multiple rate or price quotations during the year. We recommend that the District follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District should maintain documentation to show that they complied with these requirements. The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district.
Finding 2024-004 Type of Finding: Significant deficiency in internal controls over compliance and immaterial noncompliance. Federal Award Program: HUD Supportive Housing for Persons with Disabilities (Assistance Listing #14.181) Compliance Requirement: Procurement Criteria: Pursuant to the Uniform Guidance, for procurements of goods and services made with federal awards, River Kourt Apartments is required to have policies in place that conform with the Procurement Standards as prescribed in 2 CFR §200.318 through §200.320. River Kourt Apartments is required to follow the methods of procurement as prescribed in 2 CFR §200.320. Condition: River Kourt Apartments has written policies and procedures regarding the procurement of goods and services; however, the written procedures did not include all required elements regarding procurement procedures pursuant to 2 CFR §200.318 through §200.320. Cause: River Kourt Apartments has written policies and procedures regarding the procurement of goods and services; however, the written procedures did not include all required elements regarding procurement procedures pursuant to 2 CFR §200.318 through §200.320. Effect of Condition: This increases risk that River Kourt Apartments would not materially comply with the procurement requirement for the major program. Questioned Costs: None. Context: There were no procurements over the de minimis threshold made during the year period ended June 30, 2024; however, the written procedures did not include all required elements regarding procurement procedures pursuant to 2 CFR §200.318 through §200.320. Repeat Finding: Yes, see Finding 2023-003. Recommendation: We recommend management revise the current policies and procedures to include all required elements for procurement procedures pursuant to 2 CFR §200.318 through §200.320. Procurement methods shall follow the methods as prescribed in 2 CFR §200.320. View of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires non-federal entities must have and use documented procurement procedures as required under 2 CFR 200.320. For purchases in excess of the micro-purchase threshold, nonfederal entities must at minimum obtain price or rate quotations from an adequate number of qualified sources as determined appropriate by the non-Federal entity and must be able to document the price or rate quotations obtained as part of this process. Condition. Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Questioned Costs. None. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review its internal procedures to ensure future compliance with and appropriate document of procurement requirements vendor relationships. Responsible Official. Business Manager. Estimated Completion Date. June 30, 2025.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.
Assistance Listing # 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Fiscal year finding initially occurred: 2024 Criteria In accordance with 2 CFR 200.320, the City of Scott is required to formally bid contracts that exceed $250,000. Condition The City expended $261,009 of Coronavirus State and Local Fiscal Recovery Funds on a contract that exceeded the required threshold but was not formally bid. Cause The City expended federal funds on contracts that were not properly bid by federal guidelines. Effect As a result, the City was not in compliance with procurement requirements with questioned costs totaling $261,009. Context A sample of 19 transactions were selected for audit from a population of 29 disbursements. The test found that a vendor was not properly contracted. This resulted in questioned costs of $261,009. Recommendation The City should review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320. Management’s Corrective Action Plan The City of Scott will review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320.
Assistance Listing # 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Fiscal year finding initially occurred: 2024 Criteria In accordance with 2 CFR 200.320, the City of Scott is required to formally bid contracts that exceed $250,000. Condition The City expended $261,009 of Coronavirus State and Local Fiscal Recovery Funds on a contract that exceeded the required threshold but was not formally bid. Cause The City expended federal funds on contracts that were not properly bid by federal guidelines. Effect As a result, the City was not in compliance with procurement requirements with questioned costs totaling $261,009. Context A sample of 19 transactions were selected for audit from a population of 29 disbursements. The test found that a vendor was not properly contracted. This resulted in questioned costs of $261,009. Recommendation The City should review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320. Management’s Corrective Action Plan The City of Scott will review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320.
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
2024-001 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Federal program(s) U.S. Department of Education - Child Nutrition Cluster (10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. Cause. The District does not have the proper internal controls in place to ensure that all procurement contracts awarded to vendors have complied with federal and MDE requirements for allowable procurement methods. Effect. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Questioned Costs. While there are no questioned costs as all costs were allowable expenditures for the program, we were unable to verify appropriate selection processes as the procurement requirements and policies were not followed. Recommendation. We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. View of Responsible Officials. District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Official. LEA Business Manager Estimated Completion Date. June 30, 2025
Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Elementary and Secondary School Emergency Relief Federal Award Identification Number: S425U210026 Pass-Through Agency: Kentucky Department of Education Pass-Through Entity Identifying Numbers: 473G Assistance Listing Number: 84.425 Award Period: March 24, 2021 to September 30, 2024 Condition: We noted that proper bid procedures were not followed for a flooring replacement project that was completed during the year and whose total cost exceeded $40,000. Criteria: State and federal regulations (KRS 424.260 and 2 CFR 200.320) and Board policy requires that all like items purchased during the fiscal year exceeding $40,000 be purchased through a competitive bidding process or at state/federal contract pricing. Repeat Finding: No. Questioned Costs: $79,620 Effect: Noncompliance with KRS 424.260, 2 CFR 200.320 and Board policy. Recommendation: We recommend that the District implement procedures to ensure compliance with state and federal regulations and Board policy.
Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Elementary and Secondary School Emergency Relief Federal Award Identification Number: S425U210026 Pass-Through Agency: Kentucky Department of Education Pass-Through Entity Identifying Numbers: 473G Assistance Listing Number: 84.425 Award Period: March 24, 2021 to September 30, 2024 Condition: We noted that proper bid procedures were not followed for a flooring replacement project that was completed during the year and whose total cost exceeded $40,000. Criteria: State and federal regulations (KRS 424.260 and 2 CFR 200.320) and Board policy requires that all like items purchased during the fiscal year exceeding $40,000 be purchased through a competitive bidding process or at state/federal contract pricing. Repeat Finding: No. Questioned Costs: $79,620 Effect: Noncompliance with KRS 424.260, 2 CFR 200.320 and Board policy. Recommendation: We recommend that the District implement procedures to ensure compliance with state and federal regulations and Board policy.
Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Elementary and Secondary School Emergency Relief Federal Award Identification Number: S425U210026 Pass-Through Agency: Kentucky Department of Education Pass-Through Entity Identifying Numbers: 473G Assistance Listing Number: 84.425 Award Period: March 24, 2021 to September 30, 2024 Condition: We noted that proper bid procedures were not followed for a flooring replacement project that was completed during the year and whose total cost exceeded $40,000. Criteria: State and federal regulations (KRS 424.260 and 2 CFR 200.320) and Board policy requires that all like items purchased during the fiscal year exceeding $40,000 be purchased through a competitive bidding process or at state/federal contract pricing. Repeat Finding: No. Questioned Costs: $79,620 Effect: Noncompliance with KRS 424.260, 2 CFR 200.320 and Board policy. Recommendation: We recommend that the District implement procedures to ensure compliance with state and federal regulations and Board policy.
Procurement Federal Agency: U.S. Federal Government Federal Program Title: Integrative Activities, Research and Development Cluster Assistance Listing Number: 47.083 Federal Award Identification Number and Year: CE2559-SB-873905 A2, A3 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not complete documentation for reasonings of why they did not obtain price quotes or competitive bids prior to entering the transaction. Context: During our testing we identified 1 of the 5 contracts tested did not include adequate documentation to award the contracts without price quotations or a competitive bid process. Questioned costs: $39,160 Cause: Lack of training for procurement personnel regarding federal funds passed through State agencies to the University. Effect: Documentation for why the University did not obtain price quotes or competitive bids was not documented in a timely manner. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures and implement an additional control to document reasons for not obtaining price quotes or competitive bids prior to entering the transaction. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
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. Condition: During our testing of procurement, we sampled four contracts that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtained prior to selecting any of the vendors. 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 all four contracts tested. Effect/Questioned Cost: This resulted in roughly $122,215 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. In addition, we recommend that the District adopt a board policy that addresses procedures related to federal procurement. Views of Responsible Officials: The Purchasing department will develop and maintain procurement procedures requiring that “small purchases” of equipment or services made under a Federal award or sub-award above the micropurchase threshold require multiple quotes and that those quotes are properly documented as evidence.
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. Condition: During our testing of procurement, we sampled four contracts that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtained prior to selecting any of the vendors. 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 all four contracts tested. Effect/Questioned Cost: This resulted in roughly $122,215 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. In addition, we recommend that the District adopt a board policy that addresses procedures related to federal procurement. Views of Responsible Officials: The Purchasing department will develop and maintain procurement procedures requiring that “small purchases” of equipment or services made under a Federal award or sub-award above the micropurchase threshold require multiple quotes and that those quotes are properly documented as evidence.
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. Condition: During our testing of procurement, we sampled four contracts that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtained prior to selecting any of the vendors. 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 all four contracts tested. Effect/Questioned Cost: This resulted in roughly $122,215 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. In addition, we recommend that the District adopt a board policy that addresses procedures related to federal procurement. Views of Responsible Officials: The Purchasing department will develop and maintain procurement procedures requiring that “small purchases” of equipment or services made under a Federal award or sub-award above the micropurchase threshold require multiple quotes and that those quotes are properly documented as evidence.
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. Condition: During our testing of procurement, we sampled four contracts that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtained prior to selecting any of the vendors. 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 all four contracts tested. Effect/Questioned Cost: This resulted in roughly $122,215 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. In addition, we recommend that the District adopt a board policy that addresses procedures related to federal procurement. Views of Responsible Officials: The Purchasing department will develop and maintain procurement procedures requiring that “small purchases” of equipment or services made under a Federal award or sub-award above the micropurchase threshold require multiple quotes and that those quotes are properly documented as evidence.
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. Condition: During our testing of procurement, we sampled four contracts that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtained prior to selecting any of the vendors. 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 all four contracts tested. Effect/Questioned Cost: This resulted in roughly $122,215 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. In addition, we recommend that the District adopt a board policy that addresses procedures related to federal procurement. Views of Responsible Officials: The Purchasing department will develop and maintain procurement procedures requiring that “small purchases” of equipment or services made under a Federal award or sub-award above the micropurchase threshold require multiple quotes and that those quotes are properly documented as evidence.
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. Condition: During our testing of procurement, we sampled four contracts that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtained prior to selecting any of the vendors. 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 all four contracts tested. Effect/Questioned Cost: This resulted in roughly $122,215 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. In addition, we recommend that the District adopt a board policy that addresses procedures related to federal procurement. Views of Responsible Officials: The Purchasing department will develop and maintain procurement procedures requiring that “small purchases” of equipment or services made under a Federal award or sub-award above the micropurchase threshold require multiple quotes and that those quotes are properly documented as evidence.
Finding 2024-001: Incorrect Use of Sole Source Justification Information on the Federal Program: 59.059 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Title 2 U.S. Code of Federal Regulations (CFR) Part 200.320, paragraph 318 “General procurement standards” states noncompetitive (sole source) procurement is allowed only under the following circumstances: - The item is available only from a single source. - There is an exigent or emergency situation that will not permit delay. - The Federal awarding agency or pass-through entity expressly authorizes noncompetitive procurement in writing. - After soliciting multiple sources, competition is deemed inadequate. These rules are designed to ensure open and fair competition in Federal procurement. Condition: MCCC and Affiliate procured goods/services using sole source justification without meeting the required criteria. Specifically, the procurement records did not document why the procurement met one of the allowed exceptions under Uniform Guidance, and competitive procurement methods were not utilized when they should have been. Cause: The Organization did not adhere to its procurement policy in that it failed to perform the prescribed procurement procedures throughout the fiscal year. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to, and thus, there lies the potential that MCCC and Affiliate will not receive the best value for its purchases. The procurement process should also allow for an evaluation of potential conflicts of interest with prospective vendors and contractors. Failure to perform the proper procurement procedures could result in disallowance of Federal expenditures based on lack of fair competition. Questioned Costs: None noted. Context: 1 out of 1 samples tested did not follow the specific criteria for noncompetitive procurement. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend MCCC and Affiliate provide training to staff on the specific requirements of 2 CFR 200.320 to ensure that they are aware of the conditions under which sole source procurement is allowable.
FINDING 2024-003 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): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal 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 the one small purchase method procurement 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 $77,700 for food service equipment maintenance in FY23. 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.