Criteria The Uniform Guidance 2 CFR §200.320 sets forth the methods of procurement to be followed in the acquisition of property or services required under a Federal award or subaward, which includes formal purchase methods such as proposal or bids when the value of the property or services under a Federal financial assistance award exceeds a certain threshold, as defined. Furthermore, 2 CFR §200.320(c) provides specific circumstances in which noncompetitive procurement can be used. Condition During our audit, we noted that the Organization made subawards to entities which were subject to a formal purchase method, for which competitive processes for selection were not performed, nor was documentation of the specific criteria of 2 CFR §200.320(c) met to support noncompetitive procurements maintained. Cause Management had not updated its policies and procedures to incorporate certain pertinent sections of the procurement standards of the Uniform Guidance. Effect The lack of procurement standards in accordance with the Uniform Guidance may result in allowable cost issues. Recommendation We recommend that the Organization incorporate the procurement standards of the Uniform Guidance to its policies and procedures manual to ensure compliance with Federal standards, including 2 CFR §200.318(h) which stipulates that sufficient detail of the history of the procurement must be maintained, including the selection of the contractor. Views of Responsible Officials and Corrective Action The Organization concurs with the recommendation. As part of our current review and revision process, the Organization plans to adopt the 2 CFR §200.320 procurement guidance and develop supporting policies and procedures to ensure compliance with federal standards. Additionally, the Organization will incorporate the standards outlined in 2 CFR §200.318 to further align our operations with Uniform Guidance requirements, reinforcing our commitment to meeting federal compliance standards. The Organization has prioritized the completion and distribution of the updated financial policies and procedures, including the 2 CFR §200.320 procurement guidance by December 31, 2024.
Criteria The Uniform Guidance 2 CFR §200.320 sets forth the methods of procurement to be followed in the acquisition of property or services required under a Federal award or subaward, which includes formal purchase methods such as proposal or bids when the value of the property or services under a Federal financial assistance award exceeds a certain threshold, as defined. Furthermore, 2 CFR §200.320(c) provides specific circumstances in which noncompetitive procurement can be used. Condition During our audit, we noted that the Organization made subawards to entities which were subject to a formal purchase method, for which competitive processes for selection were not performed, nor was documentation of the specific criteria of 2 CFR §200.320(c) met to support noncompetitive procurements maintained. Cause Management had not updated its policies and procedures to incorporate certain pertinent sections of the procurement standards of the Uniform Guidance. Effect The lack of procurement standards in accordance with the Uniform Guidance may result in allowable cost issues. Recommendation We recommend that the Organization incorporate the procurement standards of the Uniform Guidance to its policies and procedures manual to ensure compliance with Federal standards, including 2 CFR §200.318(h) which stipulates that sufficient detail of the history of the procurement must be maintained, including the selection of the contractor. Views of Responsible Officials and Corrective Action The Organization concurs with the recommendation. As part of our current review and revision process, the Organization plans to adopt the 2 CFR §200.320 procurement guidance and develop supporting policies and procedures to ensure compliance with federal standards. Additionally, the Organization will incorporate the standards outlined in 2 CFR §200.318 to further align our operations with Uniform Guidance requirements, reinforcing our commitment to meeting federal compliance standards. The Organization has prioritized the completion and distribution of the updated financial policies and procedures, including the 2 CFR §200.320 procurement guidance by December 31, 2024.
Criteria The Uniform Guidance 2 CFR §200.320 sets forth the methods of procurement to be followed in the acquisition of property or services required under a Federal award or subaward, which includes formal purchase methods such as proposal or bids when the value of the property or services under a Federal financial assistance award exceeds a certain threshold, as defined. Furthermore, 2 CFR §200.320(c) provides specific circumstances in which noncompetitive procurement can be used. Condition During our audit, we noted that the Organization made subawards to entities which were subject to a formal purchase method, for which competitive processes for selection were not performed, nor was documentation of the specific criteria of 2 CFR §200.320(c) met to support noncompetitive procurements maintained. Cause Management had not updated its policies and procedures to incorporate certain pertinent sections of the procurement standards of the Uniform Guidance. Effect The lack of procurement standards in accordance with the Uniform Guidance may result in allowable cost issues. Recommendation We recommend that the Organization incorporate the procurement standards of the Uniform Guidance to its policies and procedures manual to ensure compliance with Federal standards, including 2 CFR §200.318(h) which stipulates that sufficient detail of the history of the procurement must be maintained, including the selection of the contractor. Views of Responsible Officials and Corrective Action The Organization concurs with the recommendation. As part of our current review and revision process, the Organization plans to adopt the 2 CFR §200.320 procurement guidance and develop supporting policies and procedures to ensure compliance with federal standards. Additionally, the Organization will incorporate the standards outlined in 2 CFR §200.318 to further align our operations with Uniform Guidance requirements, reinforcing our commitment to meeting federal compliance standards. The Organization has prioritized the completion and distribution of the updated financial policies and procedures, including the 2 CFR §200.320 procurement guidance by December 31, 2024.
Criteria The Uniform Guidance 2 CFR §200.320 sets forth the methods of procurement to be followed in the acquisition of property or services required under a Federal award or subaward, which includes formal purchase methods such as proposal or bids when the value of the property or services under a Federal financial assistance award exceeds a certain threshold, as defined. Furthermore, 2 CFR §200.320(c) provides specific circumstances in which noncompetitive procurement can be used. Condition During our audit, we noted that the Organization made subawards to entities which were subject to a formal purchase method, for which competitive processes for selection were not performed, nor was documentation of the specific criteria of 2 CFR §200.320(c) met to support noncompetitive procurements maintained. Cause Management had not updated its policies and procedures to incorporate certain pertinent sections of the procurement standards of the Uniform Guidance. Effect The lack of procurement standards in accordance with the Uniform Guidance may result in allowable cost issues. Recommendation We recommend that the Organization incorporate the procurement standards of the Uniform Guidance to its policies and procedures manual to ensure compliance with Federal standards, including 2 CFR §200.318(h) which stipulates that sufficient detail of the history of the procurement must be maintained, including the selection of the contractor. Views of Responsible Officials and Corrective Action The Organization concurs with the recommendation. As part of our current review and revision process, the Organization plans to adopt the 2 CFR §200.320 procurement guidance and develop supporting policies and procedures to ensure compliance with federal standards. Additionally, the Organization will incorporate the standards outlined in 2 CFR §200.318 to further align our operations with Uniform Guidance requirements, reinforcing our commitment to meeting federal compliance standards. The Organization has prioritized the completion and distribution of the updated financial policies and procedures, including the 2 CFR §200.320 procurement guidance by December 31, 2024.
Criteria The Uniform Guidance 2 CFR §200.320 sets forth the methods of procurement to be followed in the acquisition of property or services required under a Federal award or subaward, which includes formal purchase methods such as proposal or bids when the value of the property or services under a Federal financial assistance award exceeds a certain threshold, as defined. Furthermore, 2 CFR §200.320(c) provides specific circumstances in which noncompetitive procurement can be used. Condition During our audit, we noted that the Organization made subawards to entities which were subject to a formal purchase method, for which competitive processes for selection were not performed, nor was documentation of the specific criteria of 2 CFR §200.320(c) met to support noncompetitive procurements maintained. Cause Management had not updated its policies and procedures to incorporate certain pertinent sections of the procurement standards of the Uniform Guidance. Effect The lack of procurement standards in accordance with the Uniform Guidance may result in allowable cost issues. Recommendation We recommend that the Organization incorporate the procurement standards of the Uniform Guidance to its policies and procedures manual to ensure compliance with Federal standards, including 2 CFR §200.318(h) which stipulates that sufficient detail of the history of the procurement must be maintained, including the selection of the contractor. Views of Responsible Officials and Corrective Action The Organization concurs with the recommendation. As part of our current review and revision process, the Organization plans to adopt the 2 CFR §200.320 procurement guidance and develop supporting policies and procedures to ensure compliance with federal standards. Additionally, the Organization will incorporate the standards outlined in 2 CFR §200.318 to further align our operations with Uniform Guidance requirements, reinforcing our commitment to meeting federal compliance standards. The Organization has prioritized the completion and distribution of the updated financial policies and procedures, including the 2 CFR §200.320 procurement guidance by December 31, 2024.
Criteria The Uniform Guidance 2 CFR §200.320 sets forth the methods of procurement to be followed in the acquisition of property or services required under a Federal award or subaward, which includes formal purchase methods such as proposal or bids when the value of the property or services under a Federal financial assistance award exceeds a certain threshold, as defined. Furthermore, 2 CFR §200.320(c) provides specific circumstances in which noncompetitive procurement can be used. Condition During our audit, we noted that the Organization made subawards to entities which were subject to a formal purchase method, for which competitive processes for selection were not performed, nor was documentation of the specific criteria of 2 CFR §200.320(c) met to support noncompetitive procurements maintained. Cause Management had not updated its policies and procedures to incorporate certain pertinent sections of the procurement standards of the Uniform Guidance. Effect The lack of procurement standards in accordance with the Uniform Guidance may result in allowable cost issues. Recommendation We recommend that the Organization incorporate the procurement standards of the Uniform Guidance to its policies and procedures manual to ensure compliance with Federal standards, including 2 CFR §200.318(h) which stipulates that sufficient detail of the history of the procurement must be maintained, including the selection of the contractor. Views of Responsible Officials and Corrective Action The Organization concurs with the recommendation. As part of our current review and revision process, the Organization plans to adopt the 2 CFR §200.320 procurement guidance and develop supporting policies and procedures to ensure compliance with federal standards. Additionally, the Organization will incorporate the standards outlined in 2 CFR §200.318 to further align our operations with Uniform Guidance requirements, reinforcing our commitment to meeting federal compliance standards. The Organization has prioritized the completion and distribution of the updated financial policies and procedures, including the 2 CFR §200.320 procurement guidance by December 31, 2024.
Federal Agency: U.S. Department of Agriculture; U.S. Department of the Treasury Federal Program Name: Child Nutrition Cluster; Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 10.559; 21.027 Federal Award Identification Number and Year: 214RI306N1099/214RI306N1199 - 2022 Award Period: Fiscal Year 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement The Town and Coventry Public Schools must comply with procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). UG §200.318 General procurement standards. (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. §200.320 states that the non-Federal entity must use one of the prescribed methods of procurement. (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: (1) Micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (See the definition of micro-purchase in §200.1). To the maximum extent practicable, the non-Federal entity should distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micro-purchases if procedures are documented and approved by the non-Federal entity. (2) Small purchase. Procurement by small purchase is 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. (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a noncompetitive procurement can be used in accordance with §200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. 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. (2) Proposals. Either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the allowed circumstances apply. Condition The Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326 noted above. Questioned Costs None Context Although the Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326, we did not identify transactions where contracts were awarded without proper justification in 4 of 4 procurement transactions tested. Cause Management was not aware of the procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Effect The Town and Coventry Public Schools are at risk for noncompliance with Federal grants as it relates to procurement. Repeat Finding Yes Recommendation We recommend that the Town and Coventry Public Schools updates its procurement policy to include all elements identified in 2 CRF sections 200.303 and 200.318 through 200.326. Views of Responsible Officials Management agrees with this finding.
Federal Agency: U.S. Department of Agriculture; U.S. Department of the Treasury Federal Program Name: Child Nutrition Cluster; Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 10.559; 21.027 Federal Award Identification Number and Year: 214RI306N1099/214RI306N1199 - 2022 Award Period: Fiscal Year 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement The Town and Coventry Public Schools must comply with procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). UG §200.318 General procurement standards. (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. §200.320 states that the non-Federal entity must use one of the prescribed methods of procurement. (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: (1) Micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (See the definition of micro-purchase in §200.1). To the maximum extent practicable, the non-Federal entity should distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micro-purchases if procedures are documented and approved by the non-Federal entity. (2) Small purchase. Procurement by small purchase is 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. (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a noncompetitive procurement can be used in accordance with §200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. 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. (2) Proposals. Either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the allowed circumstances apply. Condition The Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326 noted above. Questioned Costs None Context Although the Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326, we did not identify transactions where contracts were awarded without proper justification in 4 of 4 procurement transactions tested. Cause Management was not aware of the procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Effect The Town and Coventry Public Schools are at risk for noncompliance with Federal grants as it relates to procurement. Repeat Finding Yes Recommendation We recommend that the Town and Coventry Public Schools updates its procurement policy to include all elements identified in 2 CRF sections 200.303 and 200.318 through 200.326. Views of Responsible Officials Management agrees with this finding.
Condition: During the test of 100% of expenditures, two (2) expenditures totaling $570,080, for the Coronavirus State and Local Fiscal Recovery Funds, the following noncompliance with the Procurement and Suspension and Debarment compliance requirement was noted: • The County failed to properly document the expenditure for one (1) of the two (2) federal expenditures totaling $500,000. They did not execute a contract or award documents, and the invoice was not itemized. This expenditure had a questioned cost of $500,000. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance with federal grant requirements and could result in a loss of federal funds. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Board of County Commissioners: The Board of County Commissioners is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration. Criteria: 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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 § 200.320 Internal Controls reads as follows: There are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319.
Finding 2022-005 Procurement, Suspension, and Debarment - Material Weakness in Internal Control and Material Noncompliance Agency U.S. Department of Treasury Pass-through Entity State of Alaska Department of Commerce, Community, and Economic Development Program ALN: No. 21.027 Coronavirus State and Local Fiscal Recovery Funds – COVID-19 Award No. AK0137 Award Year 2022 Criteria or Specific Requirement In accordance with 2 CFR section 200.320, the City is required to have and use documented procurement policies consistent with the standards of the CFR for any method of procurement used in the acquisition of property or services required under the American Rescue Plan Act. Condition Personnel at the City of Unalaska, acting under the local emergency in effect for FY22 did not follow procurement policies consistent with 2 CFR 200.320 for small purchases in FY22. Cause The City of Unalaska relaxed procurement policies per Resolution 2020-16 passed by the City Council on March 18, 2020. The relaxed procurement policies were not consistent with procurement policies per 2 CFR 200.320. Effect or potential effect The City was not in compliance with 2 CFR section 200.320 during 2022. Goods and services procured by the City under the program may not be the most cost-effective or appropriate for the City. Questioned Costs None. Context We tested the procurement for one sample selected in FY22. BDO was unable to obtain documentation for rate or quote solicitation for the selected sample and upon inquiry, identified that procurement policies at the City were relaxed during FY22. Recommendation Procurement policies should be updated and documented so that they are at least as restrictive as the policies required per the Code of Federal Regulation. Views of responsible officials and planned corrective actions Management agrees with the finding. Management will review procurement policies and update as needed to ensure they are at least as restrictive as the policies required per the Code of Federal Regulation.
2 CFR section 200.320(2i) for 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 price or rate quotations requires that competitive quotes must be obtained from an adequate number of qualified sources. Competitve price quotes for several goods and services that were above the micro-purchase thershold were not obtained.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $474.00 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Background: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.” Condition: A sample of 40 procurement transactions was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented, and applicable procurement compliance requirements were met. The following deficiencies were noted: The appropriate procurement method was not used for the dollar amount and conditions associated with one procurement transaction. The School District could not provide evidence that an adequate number of rate or price quotations was obtained from qualified sources for one small purchase expenditure reviewed. In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment compliance requirements were met. The following exception was noted: For two expenditures, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00 were identified for expenditures that did not follow the School District’s procurement procedures. Using the total population of $1,363,942.86 in procurement transactions, we project the likely questioned costs to be approximately $48,623.00. Cause: The School District did not follow its policies and procedures that govern the procurement process for federal programs. Effect: The School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Failure to appropriately implement procedures to address procurement compliance requirements could result in the expenditure of federal funds with unqualified vendors and the return of grant funds associated with these unallowable expenditures. Recommendation: The School District should evaluate and improve internal control procedures to ensure that required procurement methods are properly identified and followed. Furthermore, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $474.00 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Background: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.” Condition: A sample of 40 procurement transactions was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented, and applicable procurement compliance requirements were met. The following deficiencies were noted: The appropriate procurement method was not used for the dollar amount and conditions associated with one procurement transaction. The School District could not provide evidence that an adequate number of rate or price quotations was obtained from qualified sources for one small purchase expenditure reviewed. In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment compliance requirements were met. The following exception was noted: For two expenditures, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00 were identified for expenditures that did not follow the School District’s procurement procedures. Using the total population of $1,363,942.86 in procurement transactions, we project the likely questioned costs to be approximately $48,623.00. Cause: The School District did not follow its policies and procedures that govern the procurement process for federal programs. Effect: The School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Failure to appropriately implement procedures to address procurement compliance requirements could result in the expenditure of federal funds with unqualified vendors and the return of grant funds associated with these unallowable expenditures. Recommendation: The School District should evaluate and improve internal control procedures to ensure that required procurement methods are properly identified and followed. Furthermore, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $474.00 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Background: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.” Condition: A sample of 40 procurement transactions was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented, and applicable procurement compliance requirements were met. The following deficiencies were noted: The appropriate procurement method was not used for the dollar amount and conditions associated with one procurement transaction. The School District could not provide evidence that an adequate number of rate or price quotations was obtained from qualified sources for one small purchase expenditure reviewed. In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment compliance requirements were met. The following exception was noted: For two expenditures, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00 were identified for expenditures that did not follow the School District’s procurement procedures. Using the total population of $1,363,942.86 in procurement transactions, we project the likely questioned costs to be approximately $48,623.00. Cause: The School District did not follow its policies and procedures that govern the procurement process for federal programs. Effect: The School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Failure to appropriately implement procedures to address procurement compliance requirements could result in the expenditure of federal funds with unqualified vendors and the return of grant funds associated with these unallowable expenditures. Recommendation: The School District should evaluate and improve internal control procedures to ensure that required procurement methods are properly identified and followed. Furthermore, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.
Finding 2022-004 21.027 - Coronavirus State and Local Fiscal Recovery Funds Criteria 2 CFR Part 200.320(a)(2)(i) indicates “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.” Condition Documentation was not maintained by the County demonstrating price or rate quotations were received for the purchase of a piece of equipment. Cause The County did not maintain documentation of price and rate quotes received. Effect By not obtaining price or rate quotations, the County may pay more for goods and services than is necessary. Questioned Costs $11,000 Recommendations The County should establish and follow procurement policies and procedures to ensure the County adheres to requirements established by the Federal Government. Views of Responsible Officials The County does have procurement policies which, if followed correctly, would have prevailed. Hood River County Fair did go out for the best bid on their project unfortunately, no written documentation was stored. This was a time of transition in staff. Also, this area is mostly volunteers who were not trained. In the future, the County will ensure that everyone working on a Federally funded project is properly trained in grant and procurement policies and procedures.
Finding 2022-004 21.027 - Coronavirus State and Local Fiscal Recovery Funds Criteria 2 CFR Part 200.320(a)(2)(i) indicates “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.” Condition Documentation was not maintained by the County demonstrating price or rate quotations were received for the purchase of a piece of equipment. Cause The County did not maintain documentation of price and rate quotes received. Effect By not obtaining price or rate quotations, the County may pay more for goods and services than is necessary. Questioned Costs $11,000 Recommendations The County should establish and follow procurement policies and procedures to ensure the County adheres to requirements established by the Federal Government. Views of Responsible Officials The County does have procurement policies which, if followed correctly, would have prevailed. Hood River County Fair did go out for the best bid on their project unfortunately, no written documentation was stored. This was a time of transition in staff. Also, this area is mostly volunteers who were not trained. In the future, the County will ensure that everyone working on a Federally funded project is properly trained in grant and procurement policies and procedures.
Identification of federal program: US DEPARTMENT OF EDUCATION, passed through the Indiana Department of Education, Charter Schools Program 84.282A Criteria : In accordance with 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. In addition, in accordance with CFR 200.318(a) the non- federal entity must have and use documented procurement procedures consistent with federal procurement standards. Condition: Expenditures tested that met the small purchase threshold (purchases with a cost between $10,000 and $250,000) did not have documentation detailing the history of procurement. Cause : The School does not have procurement policies that follow federal guidelines, specifically 2 CFR 200.320 Methods of procurement to be followed. Effect : Property and equipment additions made using federal funds during the year did not have appropriate a support showing procurement policies were followed. Questioned costs: $83,864 Context: Two out of two purchases tested for procurement did not follow federal procurement methods. Recommendation : We recommend that the School institute procurement policies whereby acquisitions follow appropriate procurement steps as required by 2 CRF 200.350 and documentation of procurement decisions is maintained. View of responsible officials : See attached corrective action plan
Federal Agency: Department of Justice CFDA Cluster Nos.: 16.922 Federal Program Cluster: Equitable Sharing Program Compliance Requirement: Procurement, Suspension, and Debarment ? Noncompetitive Procurement (Sole Source Designation), Competition ? Formal Procurement Methods Type of Finding: Material Weakness Questioned Costs: $0 Criteria: 2 CFR 200.318 General Procurement Standards, 2 CFR 200.319 Competition, 2 CFR 200.320 Methods of Procurement to be Followed. (1) All procurement transactions for the acquisition of services required under federal award must be conducted in a manner providing full and open competition in compliance with the standards of section 200.319 and 200.320. Additionally, in compliance with the standards of section 200.320 (c) (2) Noncompetitive procurement, there are specific circumstances in which noncompetitive procurement can be used.
Federal Agency: U.S. Department of Energy, Bonneville Power Administration Federal Program Name: Columbia Basin Pit Tag Assistance Listing Number: 81.999 Federal Award Identification Number and Year: 00078040 REL 35 ? 2021-2022 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, per ?200.320(c), noncompetitive procurements can only be used if one of five specific circumstances are met. Documentation for that assessment must be kept. The Commission should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure noncompetitive procurements were appropriately identified as sole source procurements. Questioned costs: $134,084 Context: In a statistically valid sample, two of seven procurement selections tested, representing 50% of the noncompetitive procurements tested, did not have sufficient documentation to appropriately determine that the procurements qualified as sole source acquisitions. Upon further review of the procurements in question, they did appear to merit the use of sole source procurement, however incomplete documentation was kept to identify the procurements as such. Cause: The selections in questions were for renewals of software agreements. Sole source justification may have been completed on the initial contracts and purchases, however these documents were either not retained or were inaccessible during the audit. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat Finding: No Recommendation: We recommend the Commission design controls to ensure adequate documentation is maintained to support sole source justifications. Views of responsible officials: There is no disagreement with the audit finding.
2022?003 Procurement, Suspension, and Debarment Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553,10.555 Pass-Through-Agency: Wisconsin Department of Public Instruction Pass-Through-Numbers: 2022-312814-DPI-SB-SEVERE-546, 2022-312814-DPI-SB-546, 2022-312814-DPI-NSL-547 Award Period 07/01/2021-06/30/2022 Type of Finding: ? Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from and adequate number of qualified offerors. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: During our testing of procurement transactions of the program we noted two transactions over the District's Small Purchase threshold where an adequate number of quotes was not obtained. Additionally, we noted the district did not keep documentation of verifying suspension and debarment status for one contract. Questioned Costs: $36,052. Context: During our testing of procurement transactions of the program we noted two transactions over the District's Small Purchase threshold where an adequate number of quotes was not obtained. Additionally, we noted the district did not keep documentation of verifying suspension and debarment status for one contract. Cause: The District did not follow their Federal Funds Procurement- Federal Grants/Funds related to appropriate methods of procurement and suspension and debarment. Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the fiscally responsible way. The lack of price quotes may cause the District to overpay for supplies or services. Additionally, not verifying that an entity is not debarred or suspended could result in entering covered transactions with debarred or suspended vendors. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District follow their procurement and suspension and debarment policy related to small purchases which includes obtaining price quotes form and adequate number of vendors (at least two), and suspension and debarment policy for verifying vendors and maintaining this documentation. Views of responsible officials: There is no disagreement with finding.
2022?003 Procurement, Suspension, and Debarment Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553,10.555 Pass-Through-Agency: Wisconsin Department of Public Instruction Pass-Through-Numbers: 2022-312814-DPI-SB-SEVERE-546, 2022-312814-DPI-SB-546, 2022-312814-DPI-NSL-547 Award Period 07/01/2021-06/30/2022 Type of Finding: ? Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from and adequate number of qualified offerors. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: During our testing of procurement transactions of the program we noted two transactions over the District's Small Purchase threshold where an adequate number of quotes was not obtained. Additionally, we noted the district did not keep documentation of verifying suspension and debarment status for one contract. Questioned Costs: $36,052. Context: During our testing of procurement transactions of the program we noted two transactions over the District's Small Purchase threshold where an adequate number of quotes was not obtained. Additionally, we noted the district did not keep documentation of verifying suspension and debarment status for one contract. Cause: The District did not follow their Federal Funds Procurement- Federal Grants/Funds related to appropriate methods of procurement and suspension and debarment. Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the fiscally responsible way. The lack of price quotes may cause the District to overpay for supplies or services. Additionally, not verifying that an entity is not debarred or suspended could result in entering covered transactions with debarred or suspended vendors. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District follow their procurement and suspension and debarment policy related to small purchases which includes obtaining price quotes form and adequate number of vendors (at least two), and suspension and debarment policy for verifying vendors and maintaining this documentation. Views of responsible officials: There is no disagreement with finding.
2022?003 Procurement, Suspension, and Debarment Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553,10.555 Pass-Through-Agency: Wisconsin Department of Public Instruction Pass-Through-Numbers: 2022-312814-DPI-SB-SEVERE-546, 2022-312814-DPI-SB-546, 2022-312814-DPI-NSL-547 Award Period 07/01/2021-06/30/2022 Type of Finding: ? Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from and adequate number of qualified offerors. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: During our testing of procurement transactions of the program we noted two transactions over the District's Small Purchase threshold where an adequate number of quotes was not obtained. Additionally, we noted the district did not keep documentation of verifying suspension and debarment status for one contract. Questioned Costs: $36,052. Context: During our testing of procurement transactions of the program we noted two transactions over the District's Small Purchase threshold where an adequate number of quotes was not obtained. Additionally, we noted the district did not keep documentation of verifying suspension and debarment status for one contract. Cause: The District did not follow their Federal Funds Procurement- Federal Grants/Funds related to appropriate methods of procurement and suspension and debarment. Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the fiscally responsible way. The lack of price quotes may cause the District to overpay for supplies or services. Additionally, not verifying that an entity is not debarred or suspended could result in entering covered transactions with debarred or suspended vendors. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District follow their procurement and suspension and debarment policy related to small purchases which includes obtaining price quotes form and adequate number of vendors (at least two), and suspension and debarment policy for verifying vendors and maintaining this documentation. Views of responsible officials: There is no disagreement with finding.
2022?003 Procurement, Suspension, and Debarment Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553,10.555 Pass-Through-Agency: Wisconsin Department of Public Instruction Pass-Through-Numbers: 2022-312814-DPI-SB-SEVERE-546, 2022-312814-DPI-SB-546, 2022-312814-DPI-NSL-547 Award Period 07/01/2021-06/30/2022 Type of Finding: ? Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from and adequate number of qualified offerors. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: During our testing of procurement transactions of the program we noted two transactions over the District's Small Purchase threshold where an adequate number of quotes was not obtained. Additionally, we noted the district did not keep documentation of verifying suspension and debarment status for one contract. Questioned Costs: $36,052. Context: During our testing of procurement transactions of the program we noted two transactions over the District's Small Purchase threshold where an adequate number of quotes was not obtained. Additionally, we noted the district did not keep documentation of verifying suspension and debarment status for one contract. Cause: The District did not follow their Federal Funds Procurement- Federal Grants/Funds related to appropriate methods of procurement and suspension and debarment. Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the fiscally responsible way. The lack of price quotes may cause the District to overpay for supplies or services. Additionally, not verifying that an entity is not debarred or suspended could result in entering covered transactions with debarred or suspended vendors. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District follow their procurement and suspension and debarment policy related to small purchases which includes obtaining price quotes form and adequate number of vendors (at least two), and suspension and debarment policy for verifying vendors and maintaining this documentation. Views of responsible officials: There is no disagreement with finding.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
Criteria - District policy requires formal bidding procurement for expenditures in excess of $25,000 in compliance with 105 ILCS 5/10-20.21, unless specifically exempted. Uniform Guidance 2 CFR 200.320 also requires competitive procurement for purchases exceeding the micro-purchase threshold. Condition - We reviewed the District's purchase of playground equipment and installation in the amount of $89,100 under the ESSER III grant award. The District was unable to provide documentation supporting competitive procurement or explicit approval of exemption from competitive procurement procedures. Context - Although the District was unable to provide documentation supporting competitive procurement for the playground equipment, the December 16, 2021 Board of Education meeting minutes indicate explicit approval of the procurement in advance of work performed and payment made. Additionally, the Board of Education meeting minutes indicate performance of competitive bids for other District purchases. Effect - The District purchased $89,100 of playground equipment and installation from one vendor without obtaining bids or quotes; therefore the District cannot be sure it received teh best possible price for the equipment and installation under the ESSER program. Cause - The District has not historically used federal grant awards to fund procurements in excess of federal micro-purchase thresholds and was not aware of the competitive procurement requirements for federal awrds under uniform guidance. Recommendation - We recommend the District review their procurement policy and Uniform Guidance procurement requirements to ensure compliance with future purchases in excess of $25,000.
Criteria - District policy requires formal bidding procurement for expenditures in excess of $25,000 in compliance with 105 ILCS 5/10-20.21, unless specifically exempted. Uniform Guidance 2 CFR 200.320 also requires competitive procurement for purchases exceeding the micro-purchase threshold. Condition - We reviewed the District's purchase of playground equipment and installation in the amount of $89,100 under the ESSER III grant award. The District was unable to provide documentation supporting competitive procurement or explicit approval of exemption from competitive procurement procedures. Context - Although the District was unable to provide documentation supporting competitive procurement for the playground equipment, the December 16, 2021 Board of Education meeting minutes indicate explicit approval of the procurement in advance of work performed and payment made. Additionally, the Board of Education meeting minutes indicate performance of competitive bids for other District purchases. Effect - The District purchased $89,100 of playground equipment and installation from one vendor without obtaining bids or quotes; therefore the District cannot be sure it received teh best possible price for the equipment and installation under the ESSER program. Cause - The District has not historically used federal grant awards to fund procurements in excess of federal micro-purchase thresholds and was not aware of the competitive procurement requirements for federal awrds under uniform guidance. Recommendation - We recommend the District review their procurement policy and Uniform Guidance procurement requirements to ensure compliance with future purchases in excess of $25,000.
Criteria - District policy requires formal bidding procurement for expenditures in excess of $25,000 in compliance with 105 ILCS 5/10-20.21, unless specifically exempted. Uniform Guidance 2 CFR 200.320 also requires competitive procurement for purchases exceeding the micro-purchase threshold. Condition - We reviewed the District's purchase of playground equipment and installation in the amount of $89,100 under the ESSER III grant award. The District was unable to provide documentation supporting competitive procurement or explicit approval of exemption from competitive procurement procedures. Context - Although the District was unable to provide documentation supporting competitive procurement for the playground equipment, the December 16, 2021 Board of Education meeting minutes indicate explicit approval of the procurement in advance of work performed and payment made. Additionally, the Board of Education meeting minutes indicate performance of competitive bids for other District purchases. Effect - The District purchased $89,100 of playground equipment and installation from one vendor without obtaining bids or quotes; therefore the District cannot be sure it received teh best possible price for the equipment and installation under the ESSER program. Cause - The District has not historically used federal grant awards to fund procurements in excess of federal micro-purchase thresholds and was not aware of the competitive procurement requirements for federal awrds under uniform guidance. Recommendation - We recommend the District review their procurement policy and Uniform Guidance procurement requirements to ensure compliance with future purchases in excess of $25,000.
Criteria - District policy requires formal bidding procurement for expenditures in excess of $25,000 in compliance with 105 ILCS 5/10-20.21, unless specifically exempted. Uniform Guidance 2 CFR 200.320 also requires competitive procurement for purchases exceeding the micro-purchase threshold. Condition - We reviewed the District's purchase of playground equipment and installation in the amount of $89,100 under the ESSER III grant award. The District was unable to provide documentation supporting competitive procurement or explicit approval of exemption from competitive procurement procedures. Context - Although the District was unable to provide documentation supporting competitive procurement for the playground equipment, the December 16, 2021 Board of Education meeting minutes indicate explicit approval of the procurement in advance of work performed and payment made. Additionally, the Board of Education meeting minutes indicate performance of competitive bids for other District purchases. Effect - The District purchased $89,100 of playground equipment and installation from one vendor without obtaining bids or quotes; therefore the District cannot be sure it received teh best possible price for the equipment and installation under the ESSER program. Cause - The District has not historically used federal grant awards to fund procurements in excess of federal micro-purchase thresholds and was not aware of the competitive procurement requirements for federal awrds under uniform guidance. Recommendation - We recommend the District review their procurement policy and Uniform Guidance procurement requirements to ensure compliance with future purchases in excess of $25,000.
Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.320 requires, among other things, that specific criteria be met for the procurement of noncompetitive proposals. Procurement of noncompetitive proposals is procurement through solicitation of a proposal from only one source, also known as a sole source vendor. This method may only be used when one or more of the following circumstances apply: ? The item is available only from a single source. ? The purchase is in response to a public emergency that will not permit a delay resulting from the competitive process. ? The purchase is expressly authorized by awarding or pass-through agency in response to a written request from the non-Federal entity or after solicitation of a number of sources, competition is determined inadequate. Additionally, The Uniform Guidance federal regulations per 2 CFR section 200.320 also requires, among other things, that specific criteria be met for the procurement of professional services. Procurement of professional services are required to follow the following 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. ? Formal procurement methods require public advertising unless a non-competitive procurement can be used. To ensure compliance with these requirements, justification of the use of noncompetitive proposals and research on the availability from multiple sources must be documented. Documentation of authorization must be retained, and any initial solicitations from multiple sources which are concluded to be inadequate, and such reasoning must be documented. Universe/Population: The total population was all vendors of the Special Education Cluster whose transactions for the year ended June 30, 2022, exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the population. Based on these requirements, the population consisted of twenty-five vendors totaling $1,179,048. Conditions: Four vendors with expenditures totaling $451,259 were selected for testing. We noted one of the vendor selected for testing was deemed to be a sole source provider of hardware and software equipment by the School Board totaling $45,000. A sole source letter was obtained from the vendor, which outlined the uniqueness of the goods and services to be provided. However, it was determined that School Board did not appropriately follow the process for reviewing a sole source provider, per their federal procurement policy. Additionally, the form used by the School Board to document the justification of a sole source vendor was deemed insufficient for the following reasons: (1) an adequate analysis or comparison of like products was not properly completed and (2) the request form was not approved (i.e. no signature) by the purchasing department. For the remaining three vendors selected, we noted that payments were made for professional service in excess of procurement thresholds under Uniform Guidance which were not properly procured. Cause: The School Board did not adhere to its established procurement policy for professional services or noncompetitive proposals to sole source vendors and control and internal review process was not properly followed. Effect: Without proper internal controls over procurement to sole source or professional service vendors, the School Board may enter into contracts with vendors where the price may not be fair or reasonable. Recommendations: The School Board should strengthen controls at the program administration level to ensure appropriate consideration to competitors are given and adequate documentation is obtained with respect to procurement of professional services and sole source products in accordance with the Uniform Guidance 2 CFR section 200.320(f). This documentation should be approved by the program director, as well as the purchasing director, and retained as evidence of the internal controls over procurement.
Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.320 requires, among other things, that specific criteria be met for the procurement of noncompetitive proposals. Procurement of noncompetitive proposals is procurement through solicitation of a proposal from only one source, also known as a sole source vendor. This method may only be used when one or more of the following circumstances apply: ? The item is available only from a single source. ? The purchase is in response to a public emergency that will not permit a delay resulting from the competitive process. ? The purchase is expressly authorized by awarding or pass-through agency in response to a written request from the non-Federal entity or after solicitation of a number of sources, competition is determined inadequate. Additionally, The Uniform Guidance federal regulations per 2 CFR section 200.320 also requires, among other things, that specific criteria be met for the procurement of professional services. Procurement of professional services are required to follow the following 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. ? Formal procurement methods require public advertising unless a non-competitive procurement can be used. To ensure compliance with these requirements, justification of the use of noncompetitive proposals and research on the availability from multiple sources must be documented. Documentation of authorization must be retained, and any initial solicitations from multiple sources which are concluded to be inadequate, and such reasoning must be documented. Universe/Population: The total population was all vendors of the Special Education Cluster whose transactions for the year ended June 30, 2022, exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the population. Based on these requirements, the population consisted of twenty-five vendors totaling $1,179,048. Conditions: Four vendors with expenditures totaling $451,259 were selected for testing. We noted one of the vendor selected for testing was deemed to be a sole source provider of hardware and software equipment by the School Board totaling $45,000. A sole source letter was obtained from the vendor, which outlined the uniqueness of the goods and services to be provided. However, it was determined that School Board did not appropriately follow the process for reviewing a sole source provider, per their federal procurement policy. Additionally, the form used by the School Board to document the justification of a sole source vendor was deemed insufficient for the following reasons: (1) an adequate analysis or comparison of like products was not properly completed and (2) the request form was not approved (i.e. no signature) by the purchasing department. For the remaining three vendors selected, we noted that payments were made for professional service in excess of procurement thresholds under Uniform Guidance which were not properly procured. Cause: The School Board did not adhere to its established procurement policy for professional services or noncompetitive proposals to sole source vendors and control and internal review process was not properly followed. Effect: Without proper internal controls over procurement to sole source or professional service vendors, the School Board may enter into contracts with vendors where the price may not be fair or reasonable. Recommendations: The School Board should strengthen controls at the program administration level to ensure appropriate consideration to competitors are given and adequate documentation is obtained with respect to procurement of professional services and sole source products in accordance with the Uniform Guidance 2 CFR section 200.320(f). This documentation should be approved by the program director, as well as the purchasing director, and retained as evidence of the internal controls over procurement.
Assistance Listing Number: 84.425U Program Title: COVID-19 Education Stabilization Fund - American Rescue Plan ? ESSER III ? MFT & Operating Fund Federal Award Number: N/A Federal Award Year: 2021/2022 Pass Through Entity: Chicago Public Schools Criteria: In accordance with 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Organization is either lacking or has nonconforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our review of the Organization?s policies and procedures, which were found to be not in accordance with Uniform Guidance. Cause: The Organization was not aware of the specific Uniform Guidance requirements for certain written policies and procedures. Effect: The Organization did not have these policies and procedures in place to reasonably ensure that program functions are achieved effectively, efficiently and in compliance with Federal statutes, regulations, and the terms and conditions of the award. The Organization was not in compliance with the administrative requirements set forth in the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization design procedures and implement internal control procedures to ensure that the Uniform Guidance administrative requirements are met. Views of Responsible Officials and Corrective Action Plan: Management agrees with this finding and plans on implementing the appropriate policies and procedures in accordance with Uniform Guidance.
Assistance Listing Number: 84.425U Program Title: COVID-19 Education Stabilization Fund - American Rescue Plan ? ESSER III ? MFT & Operating Fund Federal Award Number: N/A Federal Award Year: 2021/2022 Pass Through Entity: Chicago Public Schools Criteria: In accordance with 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Organization is either lacking or has nonconforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our review of the Organization?s policies and procedures, which were found to be not in accordance with Uniform Guidance. Cause: The Organization was not aware of the specific Uniform Guidance requirements for certain written policies and procedures. Effect: The Organization did not have these policies and procedures in place to reasonably ensure that program functions are achieved effectively, efficiently and in compliance with Federal statutes, regulations, and the terms and conditions of the award. The Organization was not in compliance with the administrative requirements set forth in the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization design procedures and implement internal control procedures to ensure that the Uniform Guidance administrative requirements are met. Views of Responsible Officials and Corrective Action Plan: Management agrees with this finding and plans on implementing the appropriate policies and procedures in accordance with Uniform Guidance.
Finding 2022-001 - Procurement Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was a isolated instance within the scope of the tested population. Identification of Repeat Finding: No Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2022-001 - Procurement Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was a isolated instance within the scope of the tested population. Identification of Repeat Finding: No Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2022-001 - Procurement Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was a isolated instance within the scope of the tested population. Identification of Repeat Finding: No Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2022-001 - Procurement Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was a isolated instance within the scope of the tested population. Identification of Repeat Finding: No Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2022-001 - Procurement Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was a isolated instance within the scope of the tested population. Identification of Repeat Finding: No Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.