Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Information on Federal Programs U.S. Department of Energy - Weatherization Assistance for Low-Income Persons (passed through the North Dakota Division of Community Services, Award # 5073-DOE22-30) AL# 81.042 Criteria – Section 2 CFR sections 200.320(a) and (b) of the Uniform Guidance requires that the auditee following specific guidelines for selection of vendors in excess of the micro-purchase threshold which includes maintaining documentation related to their rationale for selections and agreement for goods and services to be provided. Condition – For the year ended June 30, 2023, we requested the entities documentation supporting rationale for a selection of vendors and signed contracts for expenditures in excess of the micro-purchase threshold. In a sample of 11 vendors selected for testing, one vendor did not have proper documentation rationale for selection and a signed contract. Cause – Internal controls are not designed to allow for the appropriate retention of documentation to support that appropriate procurement standards have been met. Effect or Potential Effect – Federal expenditures may be paid to vendors that are not in compliance with procurement standards under Uniform Guidance. Questioned Costs – Undeterminable Context – The vendor selected for testing was a long-standing relationship and while appropriate documentation may have been obtained at the start of the agreement, it was not maintained for the year under audit. Repeat Finding – This is a new finding. Recommendation – The entity should review their list of vendors to determine which fall under the Procurement, Suspension and Debarment standards and obtain any additional missing support or contracts to establish compliance.
2023-002 - Procurement, Suspension, and Debarment - Contract Bidding Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Procurement, Suspension, and Debarment) Federal program(s) U.S. Department of Agriculture - Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through Michigan Department of Education; 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. For small purchases (aggregate dollar acquisitions higher than the micropurchase threshold but lower than the simplified acquisition threshold), 2 CFR 200.320 requires recipients to obtain price or rate quotations from an adequate number of qualified sources. Condition. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. Cause. This condition was the result of an inaccurate understanding of procurement requirements by management. Effect. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Questioned Costs. $25,336 of expenditures were questioned as a result of this finding. Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. View of Responsible Officials. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Official. Director of Business and Finance
2023-002 - Procurement, Suspension, and Debarment - Contract Bidding Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Procurement, Suspension, and Debarment) Federal program(s) U.S. Department of Agriculture - Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through Michigan Department of Education; 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. For small purchases (aggregate dollar acquisitions higher than the micropurchase threshold but lower than the simplified acquisition threshold), 2 CFR 200.320 requires recipients to obtain price or rate quotations from an adequate number of qualified sources. Condition. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. Cause. This condition was the result of an inaccurate understanding of procurement requirements by management. Effect. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Questioned Costs. $25,336 of expenditures were questioned as a result of this finding. Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. View of Responsible Officials. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Official. Director of Business and Finance
2023-002 - Procurement, Suspension, and Debarment - Contract Bidding Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Procurement, Suspension, and Debarment) Federal program(s) U.S. Department of Agriculture - Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through Michigan Department of Education; 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. For small purchases (aggregate dollar acquisitions higher than the micropurchase threshold but lower than the simplified acquisition threshold), 2 CFR 200.320 requires recipients to obtain price or rate quotations from an adequate number of qualified sources. Condition. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. Cause. This condition was the result of an inaccurate understanding of procurement requirements by management. Effect. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Questioned Costs. $25,336 of expenditures were questioned as a result of this finding. Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. View of Responsible Officials. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Official. Director of Business and Finance
2023-002 - Procurement, Suspension, and Debarment - Contract Bidding Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Procurement, Suspension, and Debarment) Federal program(s) U.S. Department of Agriculture - Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through Michigan Department of Education; 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. For small purchases (aggregate dollar acquisitions higher than the micropurchase threshold but lower than the simplified acquisition threshold), 2 CFR 200.320 requires recipients to obtain price or rate quotations from an adequate number of qualified sources. Condition. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. Cause. This condition was the result of an inaccurate understanding of procurement requirements by management. Effect. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Questioned Costs. $25,336 of expenditures were questioned as a result of this finding. Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. View of Responsible Officials. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Official. Director of Business and Finance
2023-002 - Procurement, Suspension, and Debarment - Contract Bidding Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Procurement, Suspension, and Debarment) Federal program(s) U.S. Department of Agriculture - Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through Michigan Department of Education; 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. For small purchases (aggregate dollar acquisitions higher than the micropurchase threshold but lower than the simplified acquisition threshold), 2 CFR 200.320 requires recipients to obtain price or rate quotations from an adequate number of qualified sources. Condition. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. Cause. This condition was the result of an inaccurate understanding of procurement requirements by management. Effect. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Questioned Costs. $25,336 of expenditures were questioned as a result of this finding. Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. View of Responsible Officials. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Official. Director of Business and Finance
2023-002 - Procurement, Suspension, and Debarment - Contract Bidding Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Procurement, Suspension, and Debarment) Federal program(s) U.S. Department of Agriculture - Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through Michigan Department of Education; 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. For small purchases (aggregate dollar acquisitions higher than the micropurchase threshold but lower than the simplified acquisition threshold), 2 CFR 200.320 requires recipients to obtain price or rate quotations from an adequate number of qualified sources. Condition. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. Cause. This condition was the result of an inaccurate understanding of procurement requirements by management. Effect. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Questioned Costs. $25,336 of expenditures were questioned as a result of this finding. Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. View of Responsible Officials. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Official. Director of Business and Finance
2023-002 - Procurement, Suspension, and Debarment - Contract Bidding Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Procurement, Suspension, and Debarment) Federal program(s) U.S. Department of Agriculture - Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through Michigan Department of Education; 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. For small purchases (aggregate dollar acquisitions higher than the micropurchase threshold but lower than the simplified acquisition threshold), 2 CFR 200.320 requires recipients to obtain price or rate quotations from an adequate number of qualified sources. Condition. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. Cause. This condition was the result of an inaccurate understanding of procurement requirements by management. Effect. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Questioned Costs. $25,336 of expenditures were questioned as a result of this finding. Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. View of Responsible Officials. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Official. Director of Business and Finance
2023-002 - Procurement, Suspension, and Debarment - Contract Bidding Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Procurement, Suspension, and Debarment) Federal program(s) U.S. Department of Agriculture - Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through Michigan Department of Education; 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. For small purchases (aggregate dollar acquisitions higher than the micropurchase threshold but lower than the simplified acquisition threshold), 2 CFR 200.320 requires recipients to obtain price or rate quotations from an adequate number of qualified sources. Condition. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. Cause. This condition was the result of an inaccurate understanding of procurement requirements by management. Effect. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Questioned Costs. $25,336 of expenditures were questioned as a result of this finding. Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. View of Responsible Officials. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Official. Director of Business and Finance
2023-002 - Procurement, Suspension, and Debarment - Contract Bidding Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Procurement, Suspension, and Debarment) Federal program(s) U.S. Department of Agriculture - Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through Michigan Department of Education; 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. For small purchases (aggregate dollar acquisitions higher than the micropurchase threshold but lower than the simplified acquisition threshold), 2 CFR 200.320 requires recipients to obtain price or rate quotations from an adequate number of qualified sources. Condition. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. Cause. This condition was the result of an inaccurate understanding of procurement requirements by management. Effect. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Questioned Costs. $25,336 of expenditures were questioned as a result of this finding. Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. View of Responsible Officials. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Official. Director of Business and Finance
2023-002 - Procurement, Suspension, and Debarment - Contract Bidding Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Procurement, Suspension, and Debarment) Federal program(s) U.S. Department of Agriculture - Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through Michigan Department of Education; 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. For small purchases (aggregate dollar acquisitions higher than the micropurchase threshold but lower than the simplified acquisition threshold), 2 CFR 200.320 requires recipients to obtain price or rate quotations from an adequate number of qualified sources. Condition. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. Cause. This condition was the result of an inaccurate understanding of procurement requirements by management. Effect. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Questioned Costs. $25,336 of expenditures were questioned as a result of this finding. Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. View of Responsible Officials. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Official. Director of Business and Finance
2023-001: Procurement Special Education Cluster Assistance Listing Numbers – 84.027A; 84.027X; 84.173A; 84.173X Questioned Costs: Undetermined Criteria: 2 CFR 200.320 of the Uniform Guidance requires small purchases (generally above $10,000 but below $250,000) be made upon obtaining an adequate number of qualified sources as determined appropriate by the non-Federal entity and an adequate number of quotes from qualified sources. Furthermore, appendix II of the Uniform Guidance requires certain compliance matters to be included in contracts involving federal funds with vendors. Condition: The School Board purchased two instructional informational technology programs for use in its Special Education program; one for $249,000 and one for $86,000. Sufficient evidence was not provided to demonstrate that the School Board’s personnel obtained and decided upon these purchases using an adequate number of quotes. Also, the compliance matters required by appendix II were not included in the contract. Universe/population: A sampling of three product procurements whose payments during the fiscal year totaling $535,726 were selected for testing from a population of twenty-one such payments totaling $992,154. Two of the three purchases tested (and noted above in the condition caption) were found to be non-compliant with the procurement requirements of the Uniform Guidance. Effect: The School Board may be non-compliant with the requirements of the Uniform Guidance, which encourages competition to control costs. Furthermore, if the provisions of appendix II are not included then the School Board risks lacking various protections under federal law. Cause: This may be the result of a misunderstanding of the applicability of the Uniform Guidance by the grant administrator. Recommendation: Federal grant administrators and others should be reminded of the contractual and regulatory responsibilities to follow the Uniform Guidance. Adherence to the Uniform Guidance is also required by School Board policy. View of Responsible Official: The Business Department will review the Uniform Guidance requirements with all grant administrators and procurement staff to ensure compliance with federal regulations and district policy; and it will establish a more thorough review process for contracts to ensure compliance with all requirements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department of the Treasury, Coronavirus State and Local Fiscal Recovery Fund Federal Award Identification Number and Year - SLFRP2024-2001 Pass-through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The City should ensure there is a process in place, prior to theprocurement of goods and services, to verify that the City has followed its internal procurement policy pursuant to 2 CFR 200.319 and 200.320. Condition - We identified 4 expenditures, during testing, that the City did not verify were in accordance with its internal procurement policy, pursuant to 2 CFR 200.319 and 200.320 prior to entering into contracts with award funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - From July 1, 2022 through June 30, 2023, any good or service purchased by the City is subject to the City's internal procurement policy, pursuant to 2 CFR 200.319 and 200.320. We selected 22 expenditures for testing, and 4 lacked evidence of the City following its internal procurement policy. However, based on our testing, we noted that all 4 expenditures were allowable under the terms of the grant, thereby creating no questioned costs. Cause and Effect - The City is required to verify that there is a process in place to ensure all eligible expenditures adhere to its internal procurement policy, pursuant to 2 CFR 200.319 and 200.320. The City did not complete this requirement due to override of preexisting controls implemented by the City. Recommendation - We recommend that an additional internal control be put in place to ensure that all eligible expenditures adhere to the City's internal procurement policy. Views of Responsible Officials and Planned Corrective Actions - Procedures have already been put into place to ensure that each purchase adheres to the internal purchasing policies. City management and staff will continue to improve communication with and between departments to ensure all staff understand the purchasing policy.
2023-002 Procurement U.S. DEPARTMENT OF EDUCATION passed through the Louisiana Department of Education 84.027A, 84.173A Special Education Cluster 2022-2023 Award Year Grant No. 28-22-2C-39 Criteria: The Uniform Guidance federal regulations (200.320) require, among other things, that procedure for small purchases of goods and services in an amount between $10,000 to $250,000 follow the small purchase procedures and obtain an adequate number of prices/quotes. The Uniform Guidance federal regulations require when a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.955, is not suspended or debarred or otherwise excluded from participating in covered transactions. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS), (2) collecting certification from entity, (3) adding a clause or condition within the contract with the entity. In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal award entity must contain provisions that are outlined in Appendix II to Part 200, namely: A.) All contracts > $10,000 must address termination for cause and convenience by the nonfederal entity including the manner by which it will be affected and the basis for settlement. B.) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of "federally assisted construction contract" in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b ), in accordance with Executive Order 11246, "Equal Employment Opportunity" (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, "'Amending Executive Order 11246 Relating to Equal Employment Opportunity," and implementing regulations at 41 CFR part 60, '"Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor." C.) Debarment and Suspension (Executive Orders 12549 and 12689)-A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide Excluded Parties List System in the System for Award Management (SAM), in accordance with the 0MB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), "Debarment and Suspension." The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: While testing compliance with the federal procurement regulations, 3 vendors were identified with expenditures greater than $10,000 and less than $250,000 and testing was performed relating to the documentation to support the procurement process. Of the 3 vendors, 1 provided professional services and 2 provided equipment and materials and supplies during the year ended June 30, 2023. Compliance testing focused on the proper renewing and awarding of the contracts to determine compliance with the procurement regulations. The 3 contracts totaled $62,620. There was no evidence provided to demonstrate that quotes and prices were obtained for 1 of the 3 vendors or providers as required by Federal procurement regulations. Also, no evidence was provided to demonstrate that 3 of the 3 vendors were appropriately checked for suspension and debarment. Lastly, provisions of Appendix II of the Uniform Guidance were not included in 3 of the 3 contracts with federal dollars. Cause: Personnel administering the grants and those in the School Board purchasing department did not execute and enforce the revised purchasing policy containing the Uniform Guidance requirements. Effect: The School Board is not in compliance with the requirements of the Uniform Guidance Procurement regulations with respect to these purchases. Questioned Costs: None. Recommendation: We recommend for the School Board to more fully implement and follow its revised policies and procedures for purchases made with federal awards so that these required federal procurement regulations are followed. We recommend that the School Board include Appendix II to Part II Summary as applicable in their future contracts. Repeat Finding: No.
2023-002 Procurement U.S. DEPARTMENT OF EDUCATION passed through the Louisiana Department of Education 84.027A, 84.173A Special Education Cluster 2022-2023 Award Year Grant No. 28-22-2C-39 Criteria: The Uniform Guidance federal regulations (200.320) require, among other things, that procedure for small purchases of goods and services in an amount between $10,000 to $250,000 follow the small purchase procedures and obtain an adequate number of prices/quotes. The Uniform Guidance federal regulations require when a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.955, is not suspended or debarred or otherwise excluded from participating in covered transactions. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS), (2) collecting certification from entity, (3) adding a clause or condition within the contract with the entity. In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal award entity must contain provisions that are outlined in Appendix II to Part 200, namely: A.) All contracts > $10,000 must address termination for cause and convenience by the nonfederal entity including the manner by which it will be affected and the basis for settlement. B.) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of "federally assisted construction contract" in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b ), in accordance with Executive Order 11246, "Equal Employment Opportunity" (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, "'Amending Executive Order 11246 Relating to Equal Employment Opportunity," and implementing regulations at 41 CFR part 60, '"Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor." C.) Debarment and Suspension (Executive Orders 12549 and 12689)-A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide Excluded Parties List System in the System for Award Management (SAM), in accordance with the 0MB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), "Debarment and Suspension." The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: While testing compliance with the federal procurement regulations, 3 vendors were identified with expenditures greater than $10,000 and less than $250,000 and testing was performed relating to the documentation to support the procurement process. Of the 3 vendors, 1 provided professional services and 2 provided equipment and materials and supplies during the year ended June 30, 2023. Compliance testing focused on the proper renewing and awarding of the contracts to determine compliance with the procurement regulations. The 3 contracts totaled $62,620. There was no evidence provided to demonstrate that quotes and prices were obtained for 1 of the 3 vendors or providers as required by Federal procurement regulations. Also, no evidence was provided to demonstrate that 3 of the 3 vendors were appropriately checked for suspension and debarment. Lastly, provisions of Appendix II of the Uniform Guidance were not included in 3 of the 3 contracts with federal dollars. Cause: Personnel administering the grants and those in the School Board purchasing department did not execute and enforce the revised purchasing policy containing the Uniform Guidance requirements. Effect: The School Board is not in compliance with the requirements of the Uniform Guidance Procurement regulations with respect to these purchases. Questioned Costs: None. Recommendation: We recommend for the School Board to more fully implement and follow its revised policies and procedures for purchases made with federal awards so that these required federal procurement regulations are followed. We recommend that the School Board include Appendix II to Part II Summary as applicable in their future contracts. Repeat Finding: No.
2023-002 Procurement U.S. DEPARTMENT OF EDUCATION passed through the Louisiana Department of Education 84.027A, 84.173A Special Education Cluster 2022-2023 Award Year Grant No. 28-22-2C-39 Criteria: The Uniform Guidance federal regulations (200.320) require, among other things, that procedure for small purchases of goods and services in an amount between $10,000 to $250,000 follow the small purchase procedures and obtain an adequate number of prices/quotes. The Uniform Guidance federal regulations require when a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.955, is not suspended or debarred or otherwise excluded from participating in covered transactions. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS), (2) collecting certification from entity, (3) adding a clause or condition within the contract with the entity. In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal award entity must contain provisions that are outlined in Appendix II to Part 200, namely: A.) All contracts > $10,000 must address termination for cause and convenience by the nonfederal entity including the manner by which it will be affected and the basis for settlement. B.) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of "federally assisted construction contract" in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b ), in accordance with Executive Order 11246, "Equal Employment Opportunity" (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, "'Amending Executive Order 11246 Relating to Equal Employment Opportunity," and implementing regulations at 41 CFR part 60, '"Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor." C.) Debarment and Suspension (Executive Orders 12549 and 12689)-A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide Excluded Parties List System in the System for Award Management (SAM), in accordance with the 0MB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), "Debarment and Suspension." The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: While testing compliance with the federal procurement regulations, 3 vendors were identified with expenditures greater than $10,000 and less than $250,000 and testing was performed relating to the documentation to support the procurement process. Of the 3 vendors, 1 provided professional services and 2 provided equipment and materials and supplies during the year ended June 30, 2023. Compliance testing focused on the proper renewing and awarding of the contracts to determine compliance with the procurement regulations. The 3 contracts totaled $62,620. There was no evidence provided to demonstrate that quotes and prices were obtained for 1 of the 3 vendors or providers as required by Federal procurement regulations. Also, no evidence was provided to demonstrate that 3 of the 3 vendors were appropriately checked for suspension and debarment. Lastly, provisions of Appendix II of the Uniform Guidance were not included in 3 of the 3 contracts with federal dollars. Cause: Personnel administering the grants and those in the School Board purchasing department did not execute and enforce the revised purchasing policy containing the Uniform Guidance requirements. Effect: The School Board is not in compliance with the requirements of the Uniform Guidance Procurement regulations with respect to these purchases. Questioned Costs: None. Recommendation: We recommend for the School Board to more fully implement and follow its revised policies and procedures for purchases made with federal awards so that these required federal procurement regulations are followed. We recommend that the School Board include Appendix II to Part II Summary as applicable in their future contracts. Repeat Finding: No.
2023-002 Procurement U.S. DEPARTMENT OF EDUCATION passed through the Louisiana Department of Education 84.027A, 84.173A Special Education Cluster 2022-2023 Award Year Grant No. 28-22-2C-39 Criteria: The Uniform Guidance federal regulations (200.320) require, among other things, that procedure for small purchases of goods and services in an amount between $10,000 to $250,000 follow the small purchase procedures and obtain an adequate number of prices/quotes. The Uniform Guidance federal regulations require when a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.955, is not suspended or debarred or otherwise excluded from participating in covered transactions. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS), (2) collecting certification from entity, (3) adding a clause or condition within the contract with the entity. In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal award entity must contain provisions that are outlined in Appendix II to Part 200, namely: A.) All contracts > $10,000 must address termination for cause and convenience by the nonfederal entity including the manner by which it will be affected and the basis for settlement. B.) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of "federally assisted construction contract" in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b ), in accordance with Executive Order 11246, "Equal Employment Opportunity" (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, "'Amending Executive Order 11246 Relating to Equal Employment Opportunity," and implementing regulations at 41 CFR part 60, '"Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor." C.) Debarment and Suspension (Executive Orders 12549 and 12689)-A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide Excluded Parties List System in the System for Award Management (SAM), in accordance with the 0MB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), "Debarment and Suspension." The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: While testing compliance with the federal procurement regulations, 3 vendors were identified with expenditures greater than $10,000 and less than $250,000 and testing was performed relating to the documentation to support the procurement process. Of the 3 vendors, 1 provided professional services and 2 provided equipment and materials and supplies during the year ended June 30, 2023. Compliance testing focused on the proper renewing and awarding of the contracts to determine compliance with the procurement regulations. The 3 contracts totaled $62,620. There was no evidence provided to demonstrate that quotes and prices were obtained for 1 of the 3 vendors or providers as required by Federal procurement regulations. Also, no evidence was provided to demonstrate that 3 of the 3 vendors were appropriately checked for suspension and debarment. Lastly, provisions of Appendix II of the Uniform Guidance were not included in 3 of the 3 contracts with federal dollars. Cause: Personnel administering the grants and those in the School Board purchasing department did not execute and enforce the revised purchasing policy containing the Uniform Guidance requirements. Effect: The School Board is not in compliance with the requirements of the Uniform Guidance Procurement regulations with respect to these purchases. Questioned Costs: None. Recommendation: We recommend for the School Board to more fully implement and follow its revised policies and procedures for purchases made with federal awards so that these required federal procurement regulations are followed. We recommend that the School Board include Appendix II to Part II Summary as applicable in their future contracts. Repeat Finding: No.
2023-002 Procurement U.S. DEPARTMENT OF EDUCATION passed through the Louisiana Department of Education 84.027A, 84.173A Special Education Cluster 2022-2023 Award Year Grant No. 28-22-2C-39 Criteria: The Uniform Guidance federal regulations (200.320) require, among other things, that procedure for small purchases of goods and services in an amount between $10,000 to $250,000 follow the small purchase procedures and obtain an adequate number of prices/quotes. The Uniform Guidance federal regulations require when a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.955, is not suspended or debarred or otherwise excluded from participating in covered transactions. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS), (2) collecting certification from entity, (3) adding a clause or condition within the contract with the entity. In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal award entity must contain provisions that are outlined in Appendix II to Part 200, namely: A.) All contracts > $10,000 must address termination for cause and convenience by the nonfederal entity including the manner by which it will be affected and the basis for settlement. B.) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of "federally assisted construction contract" in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b ), in accordance with Executive Order 11246, "Equal Employment Opportunity" (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, "'Amending Executive Order 11246 Relating to Equal Employment Opportunity," and implementing regulations at 41 CFR part 60, '"Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor." C.) Debarment and Suspension (Executive Orders 12549 and 12689)-A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide Excluded Parties List System in the System for Award Management (SAM), in accordance with the 0MB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), "Debarment and Suspension." The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: While testing compliance with the federal procurement regulations, 3 vendors were identified with expenditures greater than $10,000 and less than $250,000 and testing was performed relating to the documentation to support the procurement process. Of the 3 vendors, 1 provided professional services and 2 provided equipment and materials and supplies during the year ended June 30, 2023. Compliance testing focused on the proper renewing and awarding of the contracts to determine compliance with the procurement regulations. The 3 contracts totaled $62,620. There was no evidence provided to demonstrate that quotes and prices were obtained for 1 of the 3 vendors or providers as required by Federal procurement regulations. Also, no evidence was provided to demonstrate that 3 of the 3 vendors were appropriately checked for suspension and debarment. Lastly, provisions of Appendix II of the Uniform Guidance were not included in 3 of the 3 contracts with federal dollars. Cause: Personnel administering the grants and those in the School Board purchasing department did not execute and enforce the revised purchasing policy containing the Uniform Guidance requirements. Effect: The School Board is not in compliance with the requirements of the Uniform Guidance Procurement regulations with respect to these purchases. Questioned Costs: None. Recommendation: We recommend for the School Board to more fully implement and follow its revised policies and procedures for purchases made with federal awards so that these required federal procurement regulations are followed. We recommend that the School Board include Appendix II to Part II Summary as applicable in their future contracts. Repeat Finding: No.
2023-002 Procurement U.S. DEPARTMENT OF EDUCATION passed through the Louisiana Department of Education 84.027A, 84.173A Special Education Cluster 2022-2023 Award Year Grant No. 28-22-2C-39 Criteria: The Uniform Guidance federal regulations (200.320) require, among other things, that procedure for small purchases of goods and services in an amount between $10,000 to $250,000 follow the small purchase procedures and obtain an adequate number of prices/quotes. The Uniform Guidance federal regulations require when a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.955, is not suspended or debarred or otherwise excluded from participating in covered transactions. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS), (2) collecting certification from entity, (3) adding a clause or condition within the contract with the entity. In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal award entity must contain provisions that are outlined in Appendix II to Part 200, namely: A.) All contracts > $10,000 must address termination for cause and convenience by the nonfederal entity including the manner by which it will be affected and the basis for settlement. B.) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of "federally assisted construction contract" in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b ), in accordance with Executive Order 11246, "Equal Employment Opportunity" (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, "'Amending Executive Order 11246 Relating to Equal Employment Opportunity," and implementing regulations at 41 CFR part 60, '"Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor." C.) Debarment and Suspension (Executive Orders 12549 and 12689)-A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide Excluded Parties List System in the System for Award Management (SAM), in accordance with the 0MB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), "Debarment and Suspension." The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: While testing compliance with the federal procurement regulations, 3 vendors were identified with expenditures greater than $10,000 and less than $250,000 and testing was performed relating to the documentation to support the procurement process. Of the 3 vendors, 1 provided professional services and 2 provided equipment and materials and supplies during the year ended June 30, 2023. Compliance testing focused on the proper renewing and awarding of the contracts to determine compliance with the procurement regulations. The 3 contracts totaled $62,620. There was no evidence provided to demonstrate that quotes and prices were obtained for 1 of the 3 vendors or providers as required by Federal procurement regulations. Also, no evidence was provided to demonstrate that 3 of the 3 vendors were appropriately checked for suspension and debarment. Lastly, provisions of Appendix II of the Uniform Guidance were not included in 3 of the 3 contracts with federal dollars. Cause: Personnel administering the grants and those in the School Board purchasing department did not execute and enforce the revised purchasing policy containing the Uniform Guidance requirements. Effect: The School Board is not in compliance with the requirements of the Uniform Guidance Procurement regulations with respect to these purchases. Questioned Costs: None. Recommendation: We recommend for the School Board to more fully implement and follow its revised policies and procedures for purchases made with federal awards so that these required federal procurement regulations are followed. We recommend that the School Board include Appendix II to Part II Summary as applicable in their future contracts. Repeat Finding: No.
Federal agency: U.S. Department of Agriculture Federal program title: Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing Number: 10.557 Pass-Through Agency: Iowa Department of Public Health, Division of Family and Community Health Pass-Through Numbers: 5883AO31 and 5881AO90E Award Period: October 1, 2017 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award contains various requirements for procurements made under federal awards. §200.318 requires a procurement policy be in place with specific requirements. §200.320 specifies the methods of procurement to be followed, including micropurchases,small purchases, sealed bids, competitive proposals, and noncompetitive proposals. Each procurement method has a threshold where quotes or bids are required to be obtained. Condition: During our testing, we noted one purchase over the micro-purchase threshold which did not have quotes as required. Context: During our testing, we noted one vendor tested over the micro purchase threshold did not have quotes obtained as required. Cause: The Medical Center contracted with the vendor who has previously done projects and remodeling for the facility to ensure the project was completed consistently with the rest of the building. As a result, the Medical Center did not obtain a second quote for the project. Effect: The Medical Center is not in compliance with the requirements of 2 CFR Part 200 §200.320. Recommendation: We recommend the Medical Center obtain quotes or bids as necessary for purchases that exceed the micro-purchase threshold. Additionally, we recommend the Medical Center maintain documentation of all quotes and bids to support the vendor chosen. In situations where there is an alternative method utilized, we recommend clearly documenting that process to ensure compliance.
Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556 Pass-Through Agency: Wisconsin Department of Instruction Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment. Questioned Costs: None Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556 Pass-Through Agency: Wisconsin Department of Instruction Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment. Questioned Costs: None Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556 Pass-Through Agency: Wisconsin Department of Instruction Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment. Questioned Costs: None Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556 Pass-Through Agency: Wisconsin Department of Instruction Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment. Questioned Costs: None Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.320 and 200.318(i); a non-federal entity must have procedures that document the rationale for the method of procurement, selection of the contract type, basis for contractor selection, and the basis for the contract price. In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing of the procurement process, we noted that college was not in compliance with the federal procurement regulations. Questioned costs: None Context: In our sample of three procurement transactions, one transaction did not have the required procurement documentation. Cause: The College had an existing contract with a vendor and thought the transaction was covered under the original procurement. Effect: The College is not in compliance with procurement requirements to properly document the procurement rationale for the method of procurement. Repeat Finding: No Recommendation: We recommend the College revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. Views of responsible officials: There is no disagreement with the audit finding.
2023‐009 (2022‐005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance, Noncompliance, and Questioned Costs greater than $25k) Funding Agency: United States Department of Education Federal Award Agreement Number: N/A Award Year: 2023 Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: $76,109 Condition: The University did not apply the correct small purchase threshold for identifying purchases that need to obtain quotes in their policy. Population $10k‐$20k not included in small purchase policy included transactions totaling $76,109. Progress on resolution of prior year finding: No progress was made. Criteria: Per 2 CFR 200.303(a) requires non‐Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro‐purchase threshold at $10,000 and requires purchases over the micro‐purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Cause: Policies are not adequate to meet federal guidelines and need to be updated. Effect: The University may unintentionally use a higher‐cost vendor when failing to obtain price or rate quotations for items over the micro‐purchase threshold.
2023‐009 (2022‐005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance, Noncompliance, and Questioned Costs greater than $25k) Funding Agency: United States Department of Education Federal Award Agreement Number: N/A Award Year: 2023 Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: $76,109 Condition: The University did not apply the correct small purchase threshold for identifying purchases that need to obtain quotes in their policy. Population $10k‐$20k not included in small purchase policy included transactions totaling $76,109. Progress on resolution of prior year finding: No progress was made. Criteria: Per 2 CFR 200.303(a) requires non‐Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro‐purchase threshold at $10,000 and requires purchases over the micro‐purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Cause: Policies are not adequate to meet federal guidelines and need to be updated. Effect: The University may unintentionally use a higher‐cost vendor when failing to obtain price or rate quotations for items over the micro‐purchase threshold.
2023‐009 (2022‐005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance, Noncompliance, and Questioned Costs greater than $25k) Funding Agency: United States Department of Education Federal Award Agreement Number: N/A Award Year: 2023 Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: $76,109 Condition: The University did not apply the correct small purchase threshold for identifying purchases that need to obtain quotes in their policy. Population $10k‐$20k not included in small purchase policy included transactions totaling $76,109. Progress on resolution of prior year finding: No progress was made. Criteria: Per 2 CFR 200.303(a) requires non‐Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro‐purchase threshold at $10,000 and requires purchases over the micro‐purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Cause: Policies are not adequate to meet federal guidelines and need to be updated. Effect: The University may unintentionally use a higher‐cost vendor when failing to obtain price or rate quotations for items over the micro‐purchase threshold.
Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: Yes Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The finding was initially identified during the conduct of the audit of the fiscal year ended June 30, 2022, which occurred in October 2022. The District was not able to remedy this finding for the fiscal year ended June 30, 2023 as the contract that the District had with the vendor was for multiple years. The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: Yes Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The finding was initially identified during the conduct of the audit of the fiscal year ended June 30, 2022, which occurred in October 2022. The District was not able to remedy this finding for the fiscal year ended June 30, 2023 as the contract that the District had with the vendor was for multiple years. The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: Yes Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The finding was initially identified during the conduct of the audit of the fiscal year ended June 30, 2022, which occurred in October 2022. The District was not able to remedy this finding for the fiscal year ended June 30, 2023 as the contract that the District had with the vendor was for multiple years. The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: Yes Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The finding was initially identified during the conduct of the audit of the fiscal year ended June 30, 2022, which occurred in October 2022. The District was not able to remedy this finding for the fiscal year ended June 30, 2023 as the contract that the District had with the vendor was for multiple years. The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: Yes Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The finding was initially identified during the conduct of the audit of the fiscal year ended June 30, 2022, which occurred in October 2022. The District was not able to remedy this finding for the fiscal year ended June 30, 2023 as the contract that the District had with the vendor was for multiple years. The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023 U.S. Department of Education Pass-Through Entity – Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: Yes, #2022-003 Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023 U.S. Department of Education Pass-Through Entity – Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: Yes, #2022-003 Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023 U.S. Department of Education Pass-Through Entity – Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: Yes, #2022-003 Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023 U.S. Department of Education Pass-Through Entity – Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: Yes, #2022-003 Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: See Corrective Action Plan on pages 84 - 85.
Identification of Federal Program 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria 2 CFR 200.320 Methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and 200.317, 200.318, and 200.319 for formal methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.320(b) Formal procurement methods. When the value of the procurement for property or services exceeds the simplified acquisition thresholf, formal procurement methods are required. Formal procurement methods require either sealed bids to be publicly solicited or requests for proposal publicized. Non-competitive procurement are only allowed if the purchase is under the micro-purchase threshold, if the item is only available from a single source, if public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation, if the Federal awarding agency or pass through agency expressly authorizes a non-competitive procurement, or if after solicitiation of a number of sources, competition is deemed inadequate. Condition The County did not follow formal procurement procedures related to the purchase of jail camera system. Cause The County followed its internal procurement policies which are less restrictive than formal procurement processes as required under 2 CFR 200.320. Potential Effect Open competition was not insured. Questioned Costs None Context The County followed their modified procurement procedure (PPCO 15.140(1) which allows for direct solicitation of bids from vendors that work with existing technology infrastructure already in place in the County in an effort to reduce cost and waste. As a result, formal procurement processes as required were not followed. Identification of a repeat finding, if applicable This is a new finding for the County Recommendations Formal procurement processes should be followed for all Federal award purchases that exceed the simplified acquisition threshold. Views of Responsible Officials The County agrees with the finding and will develop a corrective action plan.
Identification of Federal Program 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria 2 CFR 200.320 Methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and 200.317, 200.318, and 200.319 for formal methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.320(b) Formal procurement methods. When the value of the procurement for property or services exceeds the simplified acquisition thresholf, formal procurement methods are required. Formal procurement methods require either sealed bids to be publicly solicited or requests for proposal publicized. Non-competitive procurement are only allowed if the purchase is under the micro-purchase threshold, if the item is only available from a single source, if public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation, if the Federal awarding agency or pass through agency expressly authorizes a non-competitive procurement, or if after solicitiation of a number of sources, competition is deemed inadequate. Condition The County did not follow formal procurement procedures related to the purchase of jail camera system. Cause The County followed its internal procurement policies which are less restrictive than formal procurement processes as required under 2 CFR 200.320. Potential Effect Open competition was not insured. Questioned Costs None Context The County followed their modified procurement procedure (PPCO 15.140(1) which allows for direct solicitation of bids from vendors that work with existing technology infrastructure already in place in the County in an effort to reduce cost and waste. As a result, formal procurement processes as required were not followed. Identification of a repeat finding, if applicable This is a new finding for the County Recommendations Formal procurement processes should be followed for all Federal award purchases that exceed the simplified acquisition threshold. Views of Responsible Officials The County agrees with the finding and will develop a corrective action plan.
Criteria – Under Title 2 U.S. Code of Federal Regulations Part 200.319 “All procurement transaction for the acquisition of property or services required under a Federal awards must be conducted in a manner providing full and open competition consistent with eh standards of this section and 200.320” Also, as required by federal regulations in 2 CFR 200.320 and 2 CFR 200.213 “EPLS (excluded parties list system) review of vendors proposing on a federal project is requested at the time of receipt of proposal through the Federal Awarding Agency Contracting Department.” Condition/Context – For the one new vendor contract entered into during the fiscal year, the County did not follow federal procurement standards. A formal procurement method such as sealed bids, proposals or noncompetitive procurement was not performed and there was no evidence that the County verified the vendor was not suspended or debarred per the federal EPLS prior to entering the contract. We verified that the vendor was not suspended or debarred during the fiscal year 2023. Cause – The individuals overseeing contract procurement applied the normal state level requirements and was not aware the additional federal level requirements applicable due to the grant funds coming from a federal source. Effect – Without following the proper federal policies, the County may be entering into transactions with vendors that have been suspended or debarred. Repeated Finding – This is not a repeated finding. Recommendation – We recommend the County assigns a knowledgeable individual with proper training and skill to complete the procurement process and update policies and procedures for federal awards to ensure that the vendors are checked before entering into a contract. Management’s Response – We concur with the finding. Historically, the procurement process is handled at the department level and departments are expected to understand and comply with the requirements related to the funding source(s) used to procure goods and services. The Health and Human Services department followed our County procurement policy and solicited input from the State, the agency that passes WIC monies to the County, on suggestions for procuring dietitian/nutritionist services. While County policy was followed and input from the State was provided, documentation to support the procurement method used did not illustrate compliance with federal procurement standards and the service provider’s suspension and debarment status was not verified prior to entering into a contract. To mitigate this issue in the future, County Counsel reminded departments of the importance of understanding the requirements tied to the source being used to procure goods and services and to notify Counsel when federal monies are being used. Furthermore, County Counsel will include the suspension and debarment clause in the County’s standard contract templates, and the County Purchasing Policy (4-03) will be updated to reflect the importance of complying with requirements tied to a specific funding source. Lastly, County Counsel and Internal Audit will develop and provide training to departments.
Procurement and Suspension and Debarment Award Information: Grantor: U.S. Department of Transportation Assistance Listing Number: 20.509, Formula Grants for Rural Areas and Tribal Transit Program. Criteria Non-federal entities other than states, including those operating federal programs as sub-recipients of states, must follow procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This includes meeting the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors and maintaining records to document history of procurements. This also includes conducting procurement transactions in a manner providing full and open competition in accordance with 2 CFR section 200.319 including the use of micro-purchases and small purchase methods for procurements that meet the applicable criteria under 2 CFR section 200.320. Condition The District does not have documented procurement procedures in accordance with the procurement standards set out at 2 CFR sections 200.318 through 200.326. Cause Previous management did not implement and previous District policies did not include documentation of procurement procedures in accordance with federal standards. New management is in place and have commenced an ongoing project to summarize accounting related activities into an accounting procedures manual, this includes the required procurement procedures. Effect The District does not have documented procurement procedures as required by federal standards. Not having the required procurement procedures in place could lead to awarding contracts and making purchases without adequate competition. Questioned Costs No questioned costs. Recommendation We recommend that the District formally document a procurement policy in accordance with federal standards to include all general requirements such as oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, maintaining records to document history of procurements and conducting procurement transactions in a manner providing full and open competition. Management Response and Planned Corrective Action Following these findings are management’s view and corrective action plan.
Procurement and Suspension and Debarment Award Information: Grantor: U.S. Department of Transportation Assistance Listing Number: 20.509, Formula Grants for Rural Areas and Tribal Transit Program. Criteria Non-federal entities other than states, including those operating federal programs as sub-recipients of states, must follow procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This includes meeting the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors and maintaining records to document history of procurements. This also includes conducting procurement transactions in a manner providing full and open competition in accordance with 2 CFR section 200.319 including the use of micro-purchases and small purchase methods for procurements that meet the applicable criteria under 2 CFR section 200.320. Condition The District does not have documented procurement procedures in accordance with the procurement standards set out at 2 CFR sections 200.318 through 200.326. Cause Previous management did not implement and previous District policies did not include documentation of procurement procedures in accordance with federal standards. New management is in place and have commenced an ongoing project to summarize accounting related activities into an accounting procedures manual, this includes the required procurement procedures. Effect The District does not have documented procurement procedures as required by federal standards. Not having the required procurement procedures in place could lead to awarding contracts and making purchases without adequate competition. Questioned Costs No questioned costs. Recommendation We recommend that the District formally document a procurement policy in accordance with federal standards to include all general requirements such as oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, maintaining records to document history of procurements and conducting procurement transactions in a manner providing full and open competition. Management Response and Planned Corrective Action Following these findings are management’s view and corrective action plan.
2023-004 Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number: N/A Award Period: 07/01/2022 – 06/30/2023 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following their procurement policy, specifically related to small purchases and one project exceeding the $250,000 threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases and one project exceeding the $250,000 threshold. In our sample of sixteen vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for two vendors. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for two of the three vendors that were selected for testing. Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Repeat Finding: No Recommendation: We recommend the District review procedures to ensure that the District's procurement policy is consistently followed. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.
2023-004 Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number: N/A Award Period: 07/01/2022 – 06/30/2023 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following their procurement policy, specifically related to small purchases and one project exceeding the $250,000 threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases and one project exceeding the $250,000 threshold. In our sample of sixteen vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for two vendors. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for two of the three vendors that were selected for testing. Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Repeat Finding: No Recommendation: We recommend the District review procedures to ensure that the District's procurement policy is consistently followed. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.
2023-004 Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number: N/A Award Period: 07/01/2022 – 06/30/2023 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following their procurement policy, specifically related to small purchases and one project exceeding the $250,000 threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases and one project exceeding the $250,000 threshold. In our sample of sixteen vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for two vendors. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for two of the three vendors that were selected for testing. Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Repeat Finding: No Recommendation: We recommend the District review procedures to ensure that the District's procurement policy is consistently followed. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.
2023-004 Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number: N/A Award Period: 07/01/2022 – 06/30/2023 Compliance Requirement Affected: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Qualification Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following their procurement policy, specifically related to small purchases and one project exceeding the $250,000 threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases and one project exceeding the $250,000 threshold. In our sample of sixteen vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for two vendors. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for two of the three vendors that were selected for testing. Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Repeat Finding: No Recommendation: We recommend the District review procedures to ensure that the District's procurement policy is consistently followed. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.