FINDING 2022-002 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21, FY 22 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-004. Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for five of the six vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the rationale for the procurement method used, was not available for audit. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.319(a) (Uniform Guidance) states in part: "All procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section . . ." 2 CFR 200.319(a) (Revised Uniform Guidance) states in part: All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ? 200.320. . . ." 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319, for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Cause Management had not developed or implemented a system of internal control that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21, FY 22 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-004. Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for five of the six vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the rationale for the procurement method used, was not available for audit. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.319(a) (Uniform Guidance) states in part: "All procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section . . ." 2 CFR 200.319(a) (Revised Uniform Guidance) states in part: All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ? 200.320. . . ." 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319, for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Cause Management had not developed or implemented a system of internal control that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21, FY 22 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-004. Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for five of the six vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the rationale for the procurement method used, was not available for audit. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.319(a) (Uniform Guidance) states in part: "All procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section . . ." 2 CFR 200.319(a) (Revised Uniform Guidance) states in part: All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ? 200.320. . . ." 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319, for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Cause Management had not developed or implemented a system of internal control that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21, FY 22 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-004. Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for five of the six vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the rationale for the procurement method used, was not available for audit. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.319(a) (Uniform Guidance) states in part: "All procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section . . ." 2 CFR 200.319(a) (Revised Uniform Guidance) states in part: All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ? 200.320. . . ." 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319, for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Cause Management had not developed or implemented a system of internal control that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21, FY 22 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-004. Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for five of the six vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the rationale for the procurement method used, was not available for audit. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.319(a) (Uniform Guidance) states in part: "All procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section . . ." 2 CFR 200.319(a) (Revised Uniform Guidance) states in part: All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ? 200.320. . . ." 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319, for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Cause Management had not developed or implemented a system of internal control that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Reference Number: 2022-001 Federal Program Title: National Bioterrorism Hospital Preparedness Program Federal Assistance Listing Number: 93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 U3REP190604-03-00; Fiscal Year 2021-22 Name of Department: Department of Health Services Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (2 CFR) ?200.318: (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR ?200.319 states: (a) All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ? 200.320. 2 CFR ?200.320 states: 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 any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition During our audit of the Department of Health Services? (DHS) compliance with the procurement requirement for the National Bioterrorism Hospital Preparedness Program, we noted that for one (1) contract, DHS did not provide documentation related to the history of the procurement. Therefore, we were unable to determine whether DHS complied with the procurement requirements related to the method of procurement, competition, and the basis for the contract price. Cause The Director of the DHS, or designee, had delegated authority from the County Board of Supervisors to select, negotiate, and execute agreements with a maximum contract obligation not to exceed $500,000 annually per agreement, per award term. However, DHS was still required to follow the County?s procurement policies. Effect Failure to document the history of procurements results in noncompliance with the procurement requirements with 2 CFR 200.317, 200.318, 200.319 and 200.320. Questioned Costs Questioned costs were not identified. Context For the four (4) contracts selected for testing, which totaled $478,418 from a population of eleven (11) contracts with expenditures totaling $594,798, DHS did not provide documentation of the history of procurement for one (1) contract. The sample was not a statistically valid sample. Recommendation We recommend that DHS maintain records sufficient to detail the history of procurement and to ensure compliance with procurement requirements.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 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 had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. 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 the lease agreement, 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: No 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: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 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 had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. 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 the lease agreement, 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: No 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: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 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 had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. 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 the lease agreement, 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: No 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: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 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 had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. 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 the lease agreement, 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: No 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: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 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 had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. 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 the lease agreement, 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: No 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: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding 2022-003 ? Procurement Education Stabilization Fund ? AL #84.425, Year Ended June 30, 2022 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 had made a procurement through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. It was also noted that the District made a procurement through a sole source arrangement. 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 the lease agreement, 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: No 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: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and its own existing administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Compliance Requirement: Procurement and Written Policies ALN Number: 10.664 Grant Number: 18-DG-11020000-050 Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) ? 180.300 (January 1, 2021) requires non-federal entities to verify an entity is not excluded or disqualified prior to entering into a covered transaction by, ?(a) Checking SAM Exclusions; or (b) Collecting a certification from that [entity]; or (c) Adding a clause or condition to the covered transaction with that [entity].? A good internal control plan requires adequate procedures to ensure the County has proper procedures in place to verify that contractors paid with grant funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. The Uniform Guidance requires nonfederal entities that receive federal awards to establish written policies, procedures, and or/standards of conduct, except if excluded in compliance supplement. There are four basic reasons for creating an internal control system through defining and documenting processes with well written policies and procedures: 1.Compliance 2.Operational Needs 3.Managing Risks 4.Continuous Improvement Complying with laws and regulations should be a critical function of the County. Well-defined and documented processes (i.e. procedures, training manuals) along with records that demonstrate process capability can make evident an effective internal control system and compliance to Federal guidelines. Another important role of documentation of procedures is to ensure processes fundamental to the County are properly guided by County?s officials, and are consistent way that meets the County?s needs, and that are important related information and data are captured and communicated. Documentation of procedures are important for controlling process, documenting the standard work that was performed and training new employees. Condition: The County lacks certain written policies and procedures required by Uniform Guidance. Although the County has an outdated Accounting Policy, certain policies for Federal Expenditures need to be updated and added. These include: 1. Financial management (200.302) 2.Payment (200.305) 3.General procurement standards (200.318) 4.Competition (200.319) 5.Methods of procurement to be followed (200.320) 6.Compensation ? personal services (200.430) 7.Compensation ? fringe benefits (200.431) 8.Relocation costs of employees (200.464) 9.Travel costs (200.474) Cause: Appears to be the result of a lack of training coupled with limited staffing and resources. Questioned Costs: None Context for Calculation Of Questioned Costs: None Effect: Without adequate procedures to ensure contractors are not suspended, debarred or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations. Recommendation: We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor in not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and that procedures is adequately documented. Furthermore, the County should familiarize themselves with the Uniform Guidance and implement the following: 1.Develop and document all of its significant processes over federal awards. 2.Make the written policies and procedures available to all personnel and departments within the County 3.Ensure the written policies and procedures are accurate, complete, and current at all times (The Board of County Commissioners should update the policy on an annual basis.) 4.Revise policies and procedures for changes in business processes and policies over federal awards 5.Communicate significant changes to all affected personnel immediately to ensure they are aware of any revisions to their Responsibilities to the federal award. 6.Document policies and procedures to facilitate training and provide guidelines relative to federal awards for changes in personnel.
Compliance Requirement: Procurement and Written Policies ALN Number: 10.664 Grant Number: 18-DG-11020000-050 Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) ? 180.300 (January 1, 2021) requires non-federal entities to verify an entity is not excluded or disqualified prior to entering into a covered transaction by, ?(a) Checking SAM Exclusions; or (b) Collecting a certification from that [entity]; or (c) Adding a clause or condition to the covered transaction with that [entity].? A good internal control plan requires adequate procedures to ensure the County has proper procedures in place to verify that contractors paid with grant funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. The Uniform Guidance requires nonfederal entities that receive federal awards to establish written policies, procedures, and or/standards of conduct, except if excluded in compliance supplement. There are four basic reasons for creating an internal control system through defining and documenting processes with well written policies and procedures: 1.Compliance 2.Operational Needs 3.Managing Risks 4.Continuous Improvement Complying with laws and regulations should be a critical function of the County. Well-defined and documented processes (i.e. procedures, training manuals) along with records that demonstrate process capability can make evident an effective internal control system and compliance to Federal guidelines. Another important role of documentation of procedures is to ensure processes fundamental to the County are properly guided by County?s officials, and are consistent way that meets the County?s needs, and that are important related information and data are captured and communicated. Documentation of procedures are important for controlling process, documenting the standard work that was performed and training new employees. Condition: The County lacks certain written policies and procedures required by Uniform Guidance. Although the County has an outdated Accounting Policy, certain policies for Federal Expenditures need to be updated and added. These include: 1. Financial management (200.302) 2.Payment (200.305) 3.General procurement standards (200.318) 4.Competition (200.319) 5.Methods of procurement to be followed (200.320) 6.Compensation ? personal services (200.430) 7.Compensation ? fringe benefits (200.431) 8.Relocation costs of employees (200.464) 9.Travel costs (200.474) Cause: Appears to be the result of a lack of training coupled with limited staffing and resources. Questioned Costs: None Context for Calculation Of Questioned Costs: None Effect: Without adequate procedures to ensure contractors are not suspended, debarred or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations. Recommendation: We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor in not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and that procedures is adequately documented. Furthermore, the County should familiarize themselves with the Uniform Guidance and implement the following: 1.Develop and document all of its significant processes over federal awards. 2.Make the written policies and procedures available to all personnel and departments within the County 3.Ensure the written policies and procedures are accurate, complete, and current at all times (The Board of County Commissioners should update the policy on an annual basis.) 4.Revise policies and procedures for changes in business processes and policies over federal awards 5.Communicate significant changes to all affected personnel immediately to ensure they are aware of any revisions to their Responsibilities to the federal award. 6.Document policies and procedures to facilitate training and provide guidelines relative to federal awards for changes in personnel.
See Schedule of Findings and Questioned Costs for chart/table 2022-004: Procurement (Significant Deficiency) Criteria: The Authority must design internal controls to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Per 2 CFR 200.317, when procuring property and services under a Federal award, a State must follow the same policies and procedures it uses for procurements from its non-Federal funds. The State will comply with Sections 200.321, 200.322, and 200.323 and ensure that every purchase order or other contact includes any clauses required by Section 200.327. State means any state of the United States and any instrumentality thereof, which would include the Authority. Office of Management and Budget (OMB) Circular A-102 requires that all recipients establish written procurement procedures. Condition/context: During the completion of the fiscal year 2021 audit, it was identified that the Authority did not have an internal control system in place to evaluate purchase requests for compliance with procurement requirements. In January 2022, the Authority rectified the deficiency and established a control system. However, proper controls were not in place for the first six months of the fiscal year under audit. For three out of seven vendors selected for testing with purchases greater than the Authority?s $10,000 procurement threshold, we determined that the Authority had failed to properly document the procurement of goods and services as required by 2 CFR 200.317 and OMB Circular A-102. However, per our conversations with Authority personnel, each of the three purchases met a requirement for noncompetitive (sole source) procurement as provided for under Section 200.320 of the Uniform Guidance. Cause: The Authority was not aware of the procurement requirements and had not documented its reasons for noncompetitive procurement. Effect: If an entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings. (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Questioned costs: $0 Identification as a repeat finding: Yes; see prior-year finding 2021-002. Recommendation: As the Authority has implemented a control system that evaluates all purchase requests for goods and services for compliance with the Federal procurement requirements, we recommend continued compliance with the established control system. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR ?200.320. CONDITION Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. CAUSE The School?s internal controls over procurement of goods and services were not adequate. EFFECT The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. CONTEXT The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to three vendors. Additionally, for three of four vendors paid between $25,000 to $100,000, the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. RECOMMENDATION The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR ?200.320. CONDITION Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. CAUSE The School?s internal controls over procurement of goods and services were not adequate. EFFECT The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. CONTEXT The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to three vendors. Additionally, for three of four vendors paid between $25,000 to $100,000, the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. RECOMMENDATION The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 QUESTIONED COSTS N/A CONDITION The following errors were noted during testing of allowable costs, activities and procurement: ? For 1 of 3 vendors tested for procurement, only 1 quote was available for review. ? Vendors were not evaluated for suspension or debarment prior to purchases being made. ? For 3 of 12 disbursements tested, although the purchases are allowable under the grants, the purchases were not included in the grant budgets submitted to the Arizona Department of Education. Amended budgets were submitted on August 31, 2022. CRITERIA In accordance with 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 any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. In accordance with 2 CFR 200.214 Suspension and debarment, Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. In accordance with 2CFR 200.403 Factors Affecting Allowability of Costs, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: a. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c. Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d. Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e. Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f. Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also ? 200.306(b). g. Be adequately documented. See also ?? 200.300 through 200.309 of this part. h. Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3). In accordance with OMB Compliance Supplement, Part 6 ? Internal Control, non-Federal entities receiving Federal awards establish and maintain internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. EFFECT Program requirements were not complied with. The School may not have received the best pricing for goods or services. CAUSE Procurement procedures were not established to ensure compliance with federal regulations, including retention of quotes from an adequate number of vendors and suspension and debarment requirements. Additionally, internal controls were not designed appropriately to ensure that expenditures charged to the grant were periodically compared to the grant budgets to determine if budget amendments should be submitted. RECOMMENDATION AND BENEFIT A control system should be developed and implemented to monitor when federal expenditures require procurement, that all documentation is obtained and retained and vendors are reviewed for suspension and debarment. Additionally, internal controls should be modified to periodically compare actual expenditures under the grant with submitted budgets. This will help ensure that program requirements are complied with, the School only uses vendors that have not been suspended or debarred and budget amendments are submitted timely. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 QUESTIONED COSTS N/A CONDITION The following errors were noted during testing of allowable costs, activities and procurement: ? For 1 of 3 vendors tested for procurement, only 1 quote was available for review. ? Vendors were not evaluated for suspension or debarment prior to purchases being made. ? For 3 of 12 disbursements tested, although the purchases are allowable under the grants, the purchases were not included in the grant budgets submitted to the Arizona Department of Education. Amended budgets were submitted on August 31, 2022. CRITERIA In accordance with 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 any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. In accordance with 2 CFR 200.214 Suspension and debarment, Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. In accordance with 2CFR 200.403 Factors Affecting Allowability of Costs, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: a. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c. Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d. Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e. Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f. Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also ? 200.306(b). g. Be adequately documented. See also ?? 200.300 through 200.309 of this part. h. Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3). In accordance with OMB Compliance Supplement, Part 6 ? Internal Control, non-Federal entities receiving Federal awards establish and maintain internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. EFFECT Program requirements were not complied with. The School may not have received the best pricing for goods or services. CAUSE Procurement procedures were not established to ensure compliance with federal regulations, including retention of quotes from an adequate number of vendors and suspension and debarment requirements. Additionally, internal controls were not designed appropriately to ensure that expenditures charged to the grant were periodically compared to the grant budgets to determine if budget amendments should be submitted. RECOMMENDATION AND BENEFIT A control system should be developed and implemented to monitor when federal expenditures require procurement, that all documentation is obtained and retained and vendors are reviewed for suspension and debarment. Additionally, internal controls should be modified to periodically compare actual expenditures under the grant with submitted budgets. This will help ensure that program requirements are complied with, the School only uses vendors that have not been suspended or debarred and budget amendments are submitted timely. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Modified Opinion, Noncompliance Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: There were two small purchase method procurements selected for sample testing for the audit period. One procurement was performed by the School?s Service Center, Wilson Education Center (Service Center). During the 2020-2021 school year, the Service Center solicited, evaluated, and awarded a bid for the milk on behalf of its members that School Corporation used. The Service Center was not audited for the 2020-2021 school year. During our testing of procurement and suspension and debarment for 2020-2021, it was noted that the School Corporation was not have a review control in place to monitor that the Service Center performed all necessary procedures to maintain compliance with federal regulations surrounding procurement and suspension and debarment. For 2020-2021, the School Corporation obtained procurement documents from the Service Center supporting procurements performed during the audit period. There was no documented review control in place at the School Corporation to ensure proper monitoring of the Service Center activities occur to verify federal procurement regulations were followed by the Service Center. There was one vendor that exceeded the $10,000 threshold for the School Corporation during fiscal year 2020-2021 that would require a procurement check. The error in the sample procurement performed by the Service Center selected for testing was isolated to fiscal year 2020-2021. The amount paid to the vendor for 2020-2021 was $22,211. The vendor did not met the suspension and debarment threshold ($25,000) for fiscal year 2020-2021. Proper controls over the same vendor selected for procurement and debarment and suspension were in place for the fiscal year 2021-2022 The second procurement selected for testing was a small purchase performed by the School Corporation for food purchases totaling $103,671 in fiscal year 2020-2021 and $142,368 in fiscal year 2021-2022. We noted that the School Corporation did not obtain three quotes from separate vendors. Additionally, the School Corporation did not perform a suspension and debarment check on the vendor sampled for fiscal years 2020-2021 and 2021-2022. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish controls to ensure compliance with Procurement and Suspension and Debarment compliance requirement. We recommend that management meet periodically with the Wilson Education Center and review and maintain procurement contract files as evidence of proper periodic monitoring of the Service Center. Additionally, we recommended that the School Corporation's management establish a system of internal controls related to ensure that 3 quotes are obtained as required for small purchase method procurements and to ensure the vendors are not debarred or suspended for small purchases procurements performed by the School Corporation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Modified Opinion, Noncompliance Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: There were two small purchase method procurements selected for sample testing for the audit period. One procurement was performed by the School?s Service Center, Wilson Education Center (Service Center). During the 2020-2021 school year, the Service Center solicited, evaluated, and awarded a bid for the milk on behalf of its members that School Corporation used. The Service Center was not audited for the 2020-2021 school year. During our testing of procurement and suspension and debarment for 2020-2021, it was noted that the School Corporation was not have a review control in place to monitor that the Service Center performed all necessary procedures to maintain compliance with federal regulations surrounding procurement and suspension and debarment. For 2020-2021, the School Corporation obtained procurement documents from the Service Center supporting procurements performed during the audit period. There was no documented review control in place at the School Corporation to ensure proper monitoring of the Service Center activities occur to verify federal procurement regulations were followed by the Service Center. There was one vendor that exceeded the $10,000 threshold for the School Corporation during fiscal year 2020-2021 that would require a procurement check. The error in the sample procurement performed by the Service Center selected for testing was isolated to fiscal year 2020-2021. The amount paid to the vendor for 2020-2021 was $22,211. The vendor did not met the suspension and debarment threshold ($25,000) for fiscal year 2020-2021. Proper controls over the same vendor selected for procurement and debarment and suspension were in place for the fiscal year 2021-2022 The second procurement selected for testing was a small purchase performed by the School Corporation for food purchases totaling $103,671 in fiscal year 2020-2021 and $142,368 in fiscal year 2021-2022. We noted that the School Corporation did not obtain three quotes from separate vendors. Additionally, the School Corporation did not perform a suspension and debarment check on the vendor sampled for fiscal years 2020-2021 and 2021-2022. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish controls to ensure compliance with Procurement and Suspension and Debarment compliance requirement. We recommend that management meet periodically with the Wilson Education Center and review and maintain procurement contract files as evidence of proper periodic monitoring of the Service Center. Additionally, we recommended that the School Corporation's management establish a system of internal controls related to ensure that 3 quotes are obtained as required for small purchase method procurements and to ensure the vendors are not debarred or suspended for small purchases procurements performed by the School Corporation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Modified Opinion, Noncompliance Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: There were two small purchase method procurements selected for sample testing for the audit period. One procurement was performed by the School?s Service Center, Wilson Education Center (Service Center). During the 2020-2021 school year, the Service Center solicited, evaluated, and awarded a bid for the milk on behalf of its members that School Corporation used. The Service Center was not audited for the 2020-2021 school year. During our testing of procurement and suspension and debarment for 2020-2021, it was noted that the School Corporation was not have a review control in place to monitor that the Service Center performed all necessary procedures to maintain compliance with federal regulations surrounding procurement and suspension and debarment. For 2020-2021, the School Corporation obtained procurement documents from the Service Center supporting procurements performed during the audit period. There was no documented review control in place at the School Corporation to ensure proper monitoring of the Service Center activities occur to verify federal procurement regulations were followed by the Service Center. There was one vendor that exceeded the $10,000 threshold for the School Corporation during fiscal year 2020-2021 that would require a procurement check. The error in the sample procurement performed by the Service Center selected for testing was isolated to fiscal year 2020-2021. The amount paid to the vendor for 2020-2021 was $22,211. The vendor did not met the suspension and debarment threshold ($25,000) for fiscal year 2020-2021. Proper controls over the same vendor selected for procurement and debarment and suspension were in place for the fiscal year 2021-2022 The second procurement selected for testing was a small purchase performed by the School Corporation for food purchases totaling $103,671 in fiscal year 2020-2021 and $142,368 in fiscal year 2021-2022. We noted that the School Corporation did not obtain three quotes from separate vendors. Additionally, the School Corporation did not perform a suspension and debarment check on the vendor sampled for fiscal years 2020-2021 and 2021-2022. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish controls to ensure compliance with Procurement and Suspension and Debarment compliance requirement. We recommend that management meet periodically with the Wilson Education Center and review and maintain procurement contract files as evidence of proper periodic monitoring of the Service Center. Additionally, we recommended that the School Corporation's management establish a system of internal controls related to ensure that 3 quotes are obtained as required for small purchase method procurements and to ensure the vendors are not debarred or suspended for small purchases procurements performed by the School Corporation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01, 19619-49-PN01, 20619-047-PN01, 20611-049-PN01, 21611-047-PN01, 20619-49-PN01, 21619-047- PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) " 2 CFR 200.303 states: ?When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: 1. Checking SAM Exclusions; or 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person.? 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement? ?(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited, and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply " Condition: The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement ? Simplified Acquisition The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions. The Cooperative did not have adequate procedures in place to ensure procurements for simplified acquisitions were properly advertised and bids accepted. There were two vendors who met the Simplified Acquisition threshold during the audit period; neither were properly procured. Suspension and Debarment The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the Suspension and Debarment requirements. During school year 2020, the Cooperative did not have adequate procedures in place to ensure that applicable vendors who received federal funds were not suspended or debarred from participation in federal awards programs. There were three contracted vendors during the audit period; the unit did not perform procedures to ensure the vendors were not excluded or disqualified. During the 2021 school year, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls and noncompliance related to procurement were isolated to school year 2020-2021. The lack of controls related to suspension and debarment were systemic throughout the audit period; however, the noncompliance was isolated to school year 2020-2021. Cause: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions or suspension and debarment requirements for all contracts. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01, 19619-49-PN01, 20619-047-PN01, 20611-049-PN01, 21611-047-PN01, 20619-49-PN01, 21619-047- PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) " 2 CFR 200.303 states: ?When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: 1. Checking SAM Exclusions; or 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person.? 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement? ?(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited, and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply " Condition: The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement ? Simplified Acquisition The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions. The Cooperative did not have adequate procedures in place to ensure procurements for simplified acquisitions were properly advertised and bids accepted. There were two vendors who met the Simplified Acquisition threshold during the audit period; neither were properly procured. Suspension and Debarment The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the Suspension and Debarment requirements. During school year 2020, the Cooperative did not have adequate procedures in place to ensure that applicable vendors who received federal funds were not suspended or debarred from participation in federal awards programs. There were three contracted vendors during the audit period; the unit did not perform procedures to ensure the vendors were not excluded or disqualified. During the 2021 school year, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls and noncompliance related to procurement were isolated to school year 2020-2021. The lack of controls related to suspension and debarment were systemic throughout the audit period; however, the noncompliance was isolated to school year 2020-2021. Cause: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions or suspension and debarment requirements for all contracts. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01, 19619-49-PN01, 20619-047-PN01, 20611-049-PN01, 21611-047-PN01, 20619-49-PN01, 21619-047- PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) " 2 CFR 200.303 states: ?When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: 1. Checking SAM Exclusions; or 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person.? 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement? ?(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited, and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply " Condition: The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement ? Simplified Acquisition The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions. The Cooperative did not have adequate procedures in place to ensure procurements for simplified acquisitions were properly advertised and bids accepted. There were two vendors who met the Simplified Acquisition threshold during the audit period; neither were properly procured. Suspension and Debarment The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the Suspension and Debarment requirements. During school year 2020, the Cooperative did not have adequate procedures in place to ensure that applicable vendors who received federal funds were not suspended or debarred from participation in federal awards programs. There were three contracted vendors during the audit period; the unit did not perform procedures to ensure the vendors were not excluded or disqualified. During the 2021 school year, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls and noncompliance related to procurement were isolated to school year 2020-2021. The lack of controls related to suspension and debarment were systemic throughout the audit period; however, the noncompliance was isolated to school year 2020-2021. Cause: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions or suspension and debarment requirements for all contracts. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01, 19619-49-PN01, 20619-047-PN01, 20611-049-PN01, 21611-047-PN01, 20619-49-PN01, 21619-047- PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) " 2 CFR 200.303 states: ?When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: 1. Checking SAM Exclusions; or 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person.? 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement? ?(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited, and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply " Condition: The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement ? Simplified Acquisition The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions. The Cooperative did not have adequate procedures in place to ensure procurements for simplified acquisitions were properly advertised and bids accepted. There were two vendors who met the Simplified Acquisition threshold during the audit period; neither were properly procured. Suspension and Debarment The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the Suspension and Debarment requirements. During school year 2020, the Cooperative did not have adequate procedures in place to ensure that applicable vendors who received federal funds were not suspended or debarred from participation in federal awards programs. There were three contracted vendors during the audit period; the unit did not perform procedures to ensure the vendors were not excluded or disqualified. During the 2021 school year, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls and noncompliance related to procurement were isolated to school year 2020-2021. The lack of controls related to suspension and debarment were systemic throughout the audit period; however, the noncompliance was isolated to school year 2020-2021. Cause: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions or suspension and debarment requirements for all contracts. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01, 19619-49-PN01, 20619-047-PN01, 20611-049-PN01, 21611-047-PN01, 20619-49-PN01, 21619-047- PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) " 2 CFR 200.303 states: ?When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: 1. Checking SAM Exclusions; or 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person.? 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement? ?(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited, and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply " Condition: The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement ? Simplified Acquisition The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions. The Cooperative did not have adequate procedures in place to ensure procurements for simplified acquisitions were properly advertised and bids accepted. There were two vendors who met the Simplified Acquisition threshold during the audit period; neither were properly procured. Suspension and Debarment The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the Suspension and Debarment requirements. During school year 2020, the Cooperative did not have adequate procedures in place to ensure that applicable vendors who received federal funds were not suspended or debarred from participation in federal awards programs. There were three contracted vendors during the audit period; the unit did not perform procedures to ensure the vendors were not excluded or disqualified. During the 2021 school year, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls and noncompliance related to procurement were isolated to school year 2020-2021. The lack of controls related to suspension and debarment were systemic throughout the audit period; however, the noncompliance was isolated to school year 2020-2021. Cause: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions or suspension and debarment requirements for all contracts. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01, 19619-49-PN01, 20619-047-PN01, 20611-049-PN01, 21611-047-PN01, 20619-49-PN01, 21619-047- PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) " 2 CFR 200.303 states: ?When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: 1. Checking SAM Exclusions; or 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person.? 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement? ?(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited, and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply " Condition: The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement ? Simplified Acquisition The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions. The Cooperative did not have adequate procedures in place to ensure procurements for simplified acquisitions were properly advertised and bids accepted. There were two vendors who met the Simplified Acquisition threshold during the audit period; neither were properly procured. Suspension and Debarment The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the Suspension and Debarment requirements. During school year 2020, the Cooperative did not have adequate procedures in place to ensure that applicable vendors who received federal funds were not suspended or debarred from participation in federal awards programs. There were three contracted vendors during the audit period; the unit did not perform procedures to ensure the vendors were not excluded or disqualified. During the 2021 school year, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls and noncompliance related to procurement were isolated to school year 2020-2021. The lack of controls related to suspension and debarment were systemic throughout the audit period; however, the noncompliance was isolated to school year 2020-2021. Cause: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions or suspension and debarment requirements for all contracts. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01, 19619-49-PN01, 20619-047-PN01, 20611-049-PN01, 21611-047-PN01, 20619-49-PN01, 21619-047- PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) " 2 CFR 200.303 states: ?When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: 1. Checking SAM Exclusions; or 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person.? 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement? ?(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited, and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply " Condition: The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement ? Simplified Acquisition The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions. The Cooperative did not have adequate procedures in place to ensure procurements for simplified acquisitions were properly advertised and bids accepted. There were two vendors who met the Simplified Acquisition threshold during the audit period; neither were properly procured. Suspension and Debarment The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the Suspension and Debarment requirements. During school year 2020, the Cooperative did not have adequate procedures in place to ensure that applicable vendors who received federal funds were not suspended or debarred from participation in federal awards programs. There were three contracted vendors during the audit period; the unit did not perform procedures to ensure the vendors were not excluded or disqualified. During the 2021 school year, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls and noncompliance related to procurement were isolated to school year 2020-2021. The lack of controls related to suspension and debarment were systemic throughout the audit period; however, the noncompliance was isolated to school year 2020-2021. Cause: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions or suspension and debarment requirements for all contracts. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01, 19619-49-PN01, 20619-047-PN01, 20611-049-PN01, 21611-047-PN01, 20619-49-PN01, 21619-047- PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) " 2 CFR 200.303 states: ?When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: 1. Checking SAM Exclusions; or 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person.? 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement? ?(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited, and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply " Condition: The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement ? Simplified Acquisition The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions. The Cooperative did not have adequate procedures in place to ensure procurements for simplified acquisitions were properly advertised and bids accepted. There were two vendors who met the Simplified Acquisition threshold during the audit period; neither were properly procured. Suspension and Debarment The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the Suspension and Debarment requirements. During school year 2020, the Cooperative did not have adequate procedures in place to ensure that applicable vendors who received federal funds were not suspended or debarred from participation in federal awards programs. There were three contracted vendors during the audit period; the unit did not perform procedures to ensure the vendors were not excluded or disqualified. During the 2021 school year, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls and noncompliance related to procurement were isolated to school year 2020-2021. The lack of controls related to suspension and debarment were systemic throughout the audit period; however, the noncompliance was isolated to school year 2020-2021. Cause: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions or suspension and debarment requirements for all contracts. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
COVID-19 ? Education Stabilization Fund, Assistance Listing No. 84.425 U.S. Department of Education Award Year 2021-2022 Criteria or specific requirement ? Procurement 2 CFR 200.320 Condition ? The College charged services to the institutional portion of the award that had not been procured. Questioned Costs ? ALN 84.425F - $32,061 ? Questioned costs include amounts charged to the grant for an existing contract that was not procured after the Louisiana State of Emergency for COVID-19 ended, so the noncompetitive procurement method no longer qualified. Context ? Out of $210,105 expenses that were charged to the institutional portion of the grant and were above the College?s micro-purchase threshold, 3 key items of contracts totaling $166,574, were selected for testing. Of the contracts tested, one contract was not procured in accordance with the Uniform Guidance. When the contract was originally entered into, it was not paid for with federal funds, so the College wasn?t required to follow the procurement guide lines. At the start of the pandemic, the contract was expanded to be able to provide on-line instruction, and therefore the College used the noncompetitive procurement option given the public exigency and emergency circumstance that would not permit a delay resulting from publicizing a competitive solicitation. The Louisiana State of Emergency ended in March 2022 and the College did not have a plan in place to procure the services after noncompetitive procurement flexibility ended. Effect ? Expenses were charged to the grant that were not procured in accordance with the Uniform Guidance. Cause ? The College did not follow their procurement policy for expenses charged to federal awards. Identification of repeat finding, if applicable ? N/A Recommendation ? Management should review contracts being charged to federal grants to ensure they have followed their procurement policy. Views of responsible officials and planned corrective actions ? The College concurs with the finding and recommendation and will review contracts supported by federal grants to ensure they meet institutional and federal guidelines. The College will also review our current procurement policies and make any adjustments that may be necessary.
2022-101 Lack of Appropriate Internal Controls Related to Procurement Requirements Assistance Listing Number: 10.555 and 10.553 Name of Federal Agency: United States Department of Agriculture Program Title: National School Lunch Program Compliance Requirement: Procurement Pass-through Entity: State of Florida Department of Agriculture and Consumer Services Federal Grant/Contract Number and Grant Year: N/A (2022) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Company did not obtain the necessary number of quotes for purchases over the small purchase threshold as required. The Company also does not have a process in place to verify vendors are not suspended or debarred when they are determined to be ?covered transactions.? Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, 2 CFR section 200.320(a)(2) requires that if the small purchases procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the nonfederal entity. Finally, 2 CFR 180 Subpart C requires that the nonfederal entity determine if a vendor is excluded or disqualified (i.e. suspended or debarred) before entering into a covered transaction. Cause: Staff responsible for obtaining the quotes were told to do so by management but quotes were not obtained and management did not realize this until requested for the audit. The Company staff were not aware of the requirements associated with suspension and debarment affecting purchases over $25,000. Effect: The Company may not comply with procurement compliance requirements and may purchase something from a suspended or debarred vendor. This could lead to questioned costs for the grant. Recommendation: We recommend that the Company implement appropriate review procedures to verify staff obtain quotes prior to approval of the purchase. CRI also recommends implementing procedures to verify and document vendors are not suspended or debarred prior to purchase when transactions are considered ?covered transactions.? Views of Responsible Officials and Planned Corrective Actions: The Company will implement additional procedures to make sure suspension and debarment requirements are considered as well as additional oversight procedures to verify quotes are being obtained when required. The Company has reprimanded the staff who was told to obtain the quotes and procurement procedures were taken away from the staff in the future.
2022-101 Lack of Appropriate Internal Controls Related to Procurement Requirements Assistance Listing Number: 10.555 and 10.553 Name of Federal Agency: United States Department of Agriculture Program Title: National School Lunch Program Compliance Requirement: Procurement Pass-through Entity: State of Florida Department of Agriculture and Consumer Services Federal Grant/Contract Number and Grant Year: N/A (2022) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Company did not obtain the necessary number of quotes for purchases over the small purchase threshold as required. The Company also does not have a process in place to verify vendors are not suspended or debarred when they are determined to be ?covered transactions.? Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, 2 CFR section 200.320(a)(2) requires that if the small purchases procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the nonfederal entity. Finally, 2 CFR 180 Subpart C requires that the nonfederal entity determine if a vendor is excluded or disqualified (i.e. suspended or debarred) before entering into a covered transaction. Cause: Staff responsible for obtaining the quotes were told to do so by management but quotes were not obtained and management did not realize this until requested for the audit. The Company staff were not aware of the requirements associated with suspension and debarment affecting purchases over $25,000. Effect: The Company may not comply with procurement compliance requirements and may purchase something from a suspended or debarred vendor. This could lead to questioned costs for the grant. Recommendation: We recommend that the Company implement appropriate review procedures to verify staff obtain quotes prior to approval of the purchase. CRI also recommends implementing procedures to verify and document vendors are not suspended or debarred prior to purchase when transactions are considered ?covered transactions.? Views of Responsible Officials and Planned Corrective Actions: The Company will implement additional procedures to make sure suspension and debarment requirements are considered as well as additional oversight procedures to verify quotes are being obtained when required. The Company has reprimanded the staff who was told to obtain the quotes and procurement procedures were taken away from the staff in the future.
2022-101 Lack of Appropriate Internal Controls Related to Procurement Requirements Assistance Listing Number: 10.555 and 10.553 Name of Federal Agency: United States Department of Agriculture Program Title: National School Lunch Program Compliance Requirement: Procurement Pass-through Entity: State of Florida Department of Agriculture and Consumer Services Federal Grant/Contract Number and Grant Year: N/A (2022) Finding Type: Significant Deficiency in Internal Control Known Questioned Costs: $0 Condition: The Company did not obtain the necessary number of quotes for purchases over the small purchase threshold as required. The Company also does not have a process in place to verify vendors are not suspended or debarred when they are determined to be ?covered transactions.? Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, 2 CFR section 200.320(a)(2) requires that if the small purchases procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the nonfederal entity. Finally, 2 CFR 180 Subpart C requires that the nonfederal entity determine if a vendor is excluded or disqualified (i.e. suspended or debarred) before entering into a covered transaction. Cause: Staff responsible for obtaining the quotes were told to do so by management but quotes were not obtained and management did not realize this until requested for the audit. The Company staff were not aware of the requirements associated with suspension and debarment affecting purchases over $25,000. Effect: The Company may not comply with procurement compliance requirements and may purchase something from a suspended or debarred vendor. This could lead to questioned costs for the grant. Recommendation: We recommend that the Company implement appropriate review procedures to verify staff obtain quotes prior to approval of the purchase. CRI also recommends implementing procedures to verify and document vendors are not suspended or debarred prior to purchase when transactions are considered ?covered transactions.? Views of Responsible Officials and Planned Corrective Actions: The Company will implement additional procedures to make sure suspension and debarment requirements are considered as well as additional oversight procedures to verify quotes are being obtained when required. The Company has reprimanded the staff who was told to obtain the quotes and procurement procedures were taken away from the staff in the future.
Criteria or Specific Requirement: In accordance with 2 CFR section 200.320, a non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR section 200.317 through 200.320 for any method of procurement used for the acquisition of property or services required under a federal award or sub-award. Condition: High School for Recording Arts does not have documented procurement procedures that incorporate all the requirements of 2 CFR section 200.317 through 200.320. Context: This finding impacts the internal control for over compliance with the Uniform Guidance. Questioned Costs: None reported. Effect or Potential Effect: High School for Recording Arts is not in compliance with 2 CFR section 200.317 through 200.320. Cause: High School for Recording Arts has not adopted policies and procedures required by the Uniform Guidance. Recommendation: We recommend that High School for Recording Arts adopt a written procurement policy which includes all requirements of 2 CFR section 200.317 through 200.320.
Criteria or Specific Requirement: In accordance with 2 CFR section 200.320, a non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR section 200.317 through 200.320 for any method of procurement used for the acquisition of property or services required under a federal award or sub-award. Condition: High School for Recording Arts does not have documented procurement procedures that incorporate all the requirements of 2 CFR section 200.317 through 200.320. Context: This finding impacts the internal control for over compliance with the Uniform Guidance. Questioned Costs: None reported. Effect or Potential Effect: High School for Recording Arts is not in compliance with 2 CFR section 200.317 through 200.320. Cause: High School for Recording Arts has not adopted policies and procedures required by the Uniform Guidance. Recommendation: We recommend that High School for Recording Arts adopt a written procurement policy which includes all requirements of 2 CFR section 200.317 through 200.320.
Criteria or Specific Requirement: In accordance with 2 CFR section 200.320, a non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR section 200.317 through 200.320 for any method of procurement used for the acquisition of property or services required under a federal award or sub-award. Condition: High School for Recording Arts does not have documented procurement procedures that incorporate all the requirements of 2 CFR section 200.317 through 200.320. Context: This finding impacts the internal control for over compliance with the Uniform Guidance. Questioned Costs: None reported. Effect or Potential Effect: High School for Recording Arts is not in compliance with 2 CFR section 200.317 through 200.320. Cause: High School for Recording Arts has not adopted policies and procedures required by the Uniform Guidance. Recommendation: We recommend that High School for Recording Arts adopt a written procurement policy which includes all requirements of 2 CFR section 200.317 through 200.320.
Criteria or Specific Requirement: In accordance with 2 CFR section 200.320, a non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR section 200.317 through 200.320 for any method of procurement used for the acquisition of property or services required under a federal award or sub-award. Condition: High School for Recording Arts does not have documented procurement procedures that incorporate all the requirements of 2 CFR section 200.317 through 200.320. Context: This finding impacts the internal control for over compliance with the Uniform Guidance. Questioned Costs: None reported. Effect or Potential Effect: High School for Recording Arts is not in compliance with 2 CFR section 200.317 through 200.320. Cause: High School for Recording Arts has not adopted policies and procedures required by the Uniform Guidance. Recommendation: We recommend that High School for Recording Arts adopt a written procurement policy which includes all requirements of 2 CFR section 200.317 through 200.320.
Criteria or Specific Requirement: In accordance with 2 CFR section 200.320, a non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR section 200.317 through 200.320 for any method of procurement used for the acquisition of property or services required under a federal award or sub-award. Condition: High School for Recording Arts does not have documented procurement procedures that incorporate all the requirements of 2 CFR section 200.317 through 200.320. Context: This finding impacts the internal control for over compliance with the Uniform Guidance. Questioned Costs: None reported. Effect or Potential Effect: High School for Recording Arts is not in compliance with 2 CFR section 200.317 through 200.320. Cause: High School for Recording Arts has not adopted policies and procedures required by the Uniform Guidance. Recommendation: We recommend that High School for Recording Arts adopt a written procurement policy which includes all requirements of 2 CFR section 200.317 through 200.320.
Criteria or Specific Requirement: In accordance with 2 CFR section 200.320, a non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR section 200.317 through 200.320 for any method of procurement used for the acquisition of property or services required under a federal award or sub-award. Condition: High School for Recording Arts does not have documented procurement procedures that incorporate all the requirements of 2 CFR section 200.317 through 200.320. Context: This finding impacts the internal control for over compliance with the Uniform Guidance. Questioned Costs: None reported. Effect or Potential Effect: High School for Recording Arts is not in compliance with 2 CFR section 200.317 through 200.320. Cause: High School for Recording Arts has not adopted policies and procedures required by the Uniform Guidance. Recommendation: We recommend that High School for Recording Arts adopt a written procurement policy which includes all requirements of 2 CFR section 200.317 through 200.320.
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)