CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that 1) competitive bidding was performed for the purchases of goods or services over $22,500 and 2) a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendor –– Beaver Valley Intermediate Unit ($332,200). This is a repeat procurement finding from (2023-005) from the previous fiscal year.CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District 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, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, or 4) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). QUESTIONED COST: $332,200 RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) of the Uniform Guidance regarding maintaining records sufficient to detail the history of procurement which includes rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price, 4) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, 5) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, and 5) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that 1) competitive bidding was performed for the purchases of goods or services over $22,500 and 2) a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendor –– Beaver Valley Intermediate Unit ($332,200). This is a repeat procurement finding from (2023-005) from the previous fiscal year.CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District 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, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, or 4) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). QUESTIONED COST: $332,200 RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) of the Uniform Guidance regarding maintaining records sufficient to detail the history of procurement which includes rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price, 4) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, 5) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, and 5) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
Finding 2024-001 – Procurement Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No.: No. 21.027 Federal Award Number: ASST_NON_SLFRP0137_2001 Grant Award Period: 9/1/2022 – 8/31/2024 Pass Through Entity: Los Angeles County - Department of Public Health Repeat Finding – No Statistically Valid Sample – The sample was not intended to be, and was not, a statistically valid sample Criteria 2 CFR 200.324 requires that the non-federal entity perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold, including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.303 requires the recipient of federal funds 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/Context For both of the samples selected for testing which had related procurements above the California Community Foundation’s (the Foundation's) Simplified Acquisition Threshold, there was no support evidencing a cost or price analysis performed by management before receiving the corresponding proposals, although multiple bids were received as part of these procurements. Cause Although the Foundation included the requirement in its procurement policies that the cost or price analysis needed to be performed before bids or proposals are received the Foundation did not have sufficient controls in place to ensure that a cost or price analysis is performed prior to receiving bids or proposals. Effect Because the Foundation was not in compliance with one of the procurement requirements this could result in disallowed costs if procurement amounts aren't considered reasonable. The Foundation did, however, receive multiple bids as part of the procurement process for each of the samples noted above to demonstrate the costs claimed for reimbursement under the contract were reasonable and under the budget provided to the Foundation by the passthrough awarding entity. Questioned Costs None noted. Auditors’ Recommendation We recommend that the Foundation strengthen processes and internal controls to ensure that a cost or price analysis is performed, reviewed, and substantiated with formal documentation prior to receiving bids or proposals for all procurement actions above the Simplified Acquisition Threshold. Views of Responsible Officials The Foundation acknowledges the finding and will enhance compliance with federal procurement standards by reinforcing staff training on cost and price analysis requirements, strengthening internal oversight mechanisms, and implementing a formalized process to ensure proper documentation is completed and retained. Periodic reviews and audits will verify adherence to these standards and maintain consistent implementation.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of the Treasury, COVID 19 - Coronavirus State and Local Fiscal Recovery Funds, and 93.493, U.S. Department of Health and Human Services, Congressional Directives Federal Award Identification Number and Year 21.027 192908 and 93.493 6 CE2CS52794 01 07 Pass through Entity 21.027 Chicago Department of Public Health; 93.493 N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.318(i), the nonfederal 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. Per 2 CFR 200.319(a) All procurement transactions under the federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320(b) covering formal procurement methods. Per 2 CFR 200.324(a), the nonfederal entity must perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold (SAT), including contract modifications. The method and degree of analysis is dependent upon the facts surrounding the particular procurement situation; but, as a starting point, the nonfederal entity must make independent estimates before receiving bids or proposals. Finally, per 2 CFR 180.300, nonfederal entities must verify that outside parties are not suspended or debarred from engaging in federal activity before entering into a covered transaction. Condition Controls were not sufficient to ensure procurement activities were performed in accordance with 2 CFR 200 and management’s internal policies and procedures related to procurement, suspension, and debarment. Questioned Costs $ 237,890 If Questioned Costs are not Determinable, Description of why Known Questioned Costs Were Undetermined or Otherwise Could not be Reported N/A Identification of How Questioned Costs Were Computed Questioned costs represent expenditures under these contracts reported on the SEFA. Context For three contracts in excess of the Organization's formal procurement threshold ($50,000), management did not retain documentation of having obtained the required number of competitive bids or document rationale for sole procurement, did not document the history of procurement decisions, and was unable to provide evidence that contractors were checked for suspension and debarment in advance of entering into a covered transaction. Cause and Effect A lack of controls to ensure required procurement activities were performed could result in material noncompliance with federal procurement standards. Recommendation We recommend that management retain documented evidence that its policies and procedures were followed to ensure compliance with federal procurement standards. Additionally, we recommend management review its internal procurement policy regularly to ensure compliance with federal procurement standards under 2 CFR 200.317 through 200.327. Views of Responsible Officials and Corrective Action Plan Management agrees with the recommendation and will review the relevant guidance to ensure compliance. Careful consideration was done in selecting the vendors to look at obtaining the best cost for the value of the service as IWS was responsible for a portion of the expenses. Necessary revisions will be made to the existing procurement processes and controls in a timely manner to ensure that procurement decisions are documented, as required by 2 CFR Part 200.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of the Treasury, COVID 19 - Coronavirus State and Local Fiscal Recovery Funds, and 93.493, U.S. Department of Health and Human Services, Congressional Directives Federal Award Identification Number and Year 21.027 192908 and 93.493 6 CE2CS52794 01 07 Pass through Entity 21.027 Chicago Department of Public Health; 93.493 N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.318(i), the nonfederal 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. Per 2 CFR 200.319(a) All procurement transactions under the federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320(b) covering formal procurement methods. Per 2 CFR 200.324(a), the nonfederal entity must perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold (SAT), including contract modifications. The method and degree of analysis is dependent upon the facts surrounding the particular procurement situation; but, as a starting point, the nonfederal entity must make independent estimates before receiving bids or proposals. Finally, per 2 CFR 180.300, nonfederal entities must verify that outside parties are not suspended or debarred from engaging in federal activity before entering into a covered transaction. Condition Controls were not sufficient to ensure procurement activities were performed in accordance with 2 CFR 200 and management’s internal policies and procedures related to procurement, suspension, and debarment. Questioned Costs $ 237,890 If Questioned Costs are not Determinable, Description of why Known Questioned Costs Were Undetermined or Otherwise Could not be Reported N/A Identification of How Questioned Costs Were Computed Questioned costs represent expenditures under these contracts reported on the SEFA. Context For three contracts in excess of the Organization's formal procurement threshold ($50,000), management did not retain documentation of having obtained the required number of competitive bids or document rationale for sole procurement, did not document the history of procurement decisions, and was unable to provide evidence that contractors were checked for suspension and debarment in advance of entering into a covered transaction. Cause and Effect A lack of controls to ensure required procurement activities were performed could result in material noncompliance with federal procurement standards. Recommendation We recommend that management retain documented evidence that its policies and procedures were followed to ensure compliance with federal procurement standards. Additionally, we recommend management review its internal procurement policy regularly to ensure compliance with federal procurement standards under 2 CFR 200.317 through 200.327. Views of Responsible Officials and Corrective Action Plan Management agrees with the recommendation and will review the relevant guidance to ensure compliance. Careful consideration was done in selecting the vendors to look at obtaining the best cost for the value of the service as IWS was responsible for a portion of the expenses. Necessary revisions will be made to the existing procurement processes and controls in a timely manner to ensure that procurement decisions are documented, as required by 2 CFR Part 200.
Procurement and Suspension and Debarment Finding Number: 2024-003 Assistance Listing Number and Title COVID-19 Coronavirus State and Local Fiscal Recovery Funds – AL #21.027 Federal Award Identification Number / Year: 2024 Federal Agency: U.S. Department of Treasury Compliance Requirement: Procurement and Suspension and Debarment Pass-Through Entity: Ohio Facilities Construction Commission Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR 1000.10 gives regulatory effect to the U.S. Department of Treasury for 2 CFR § 200.318 through 200.327 which describe specific procedures non-Federal entities must follow when entering into procurement transactions using Federal funds. 2 CFR 200.324(a) requires a cost or price analysis be performed for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. 2 CFR 200.324(c) states that the “cost plus a percentage of cost” and “percentage of construction costs” methods of contracting must not be used. Additionally, District Policy: PROCUREMENT - FEDERAL GRANTS/FUNDS, states that the District shall perform a cost or price analysis in connection with every procurement action in excess of $250,000, including contract modifications. A cost analysis generally means evaluating the separate cost elements that make up the total price, while a price analysis means evaluating the total price, without looking at the individual cost elements. The method and degree of analysis are dependent on the facts surrounding the particular procurement situation; however, the District shall come to an independent estimate prior to receiving bids or proposals. The District did not have the proper internal controls in place to perform a cost or price analysis for procurements in excess of $250,000. During testing of Ohio K-12 School Safety Grant – Public School Districts, we noted the District used the sealed bid procurement to award a project in excess of $250,000, and there was no evidence the District performed a cost or price analysis. Due to the deficient internal control structure, the required cost or price analysis was not completed for the procurement action covering a transaction made in Fiscal Year 2024. Failing to have the appropriate controls in place may result in rewarding contracts to vendors whose bids or proposals are not the most responsive and responsible. The District should perform a cost or price analysis for all procurement actions in excess of $250,000.
2024 – 007 Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Department of Interior Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds (ARPA) Outdoor Recreation Acquisition, Development and Planning ALN: 21.027 15.916 Pass-Through Agency: Coronavirus State and Local Fiscal Recovery Funds (ARPA) N/A Outdoor Recreation Acquisition, Development and Planning Arizona State Park Trails Pass-Through Number(s): Coronavirus State and Local Fiscal Recovery Funds (ARPA) N/A Outdoor Recreation Acquisition, Development and Planning 04-007-652304 Award Number and Period: Coronavirus State and Local Fiscal Recovery Funds (ARPA) 1505-0271 3/3/2021 – 12/31/2024 Outdoor Recreation Acquisition, Development and Planning 04/18/2022-12/31/24 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), the City of Nogales must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it 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 the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.324, the non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non- Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by: (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The following is a summary results for each audited program. Coronavirus State and Local Fiscal Recovery Funds (ARPA) - Audit procedures included selection and testing of five competitively procured vendor contracts. Three out of five vendors tested for procurement did not provide support for the procurement method used, price/bid comparison, and cost analysis performed. One out of five vendors tested did not have a valid contract on file. Five out of five vendors tested did not provide support for the SAMS verification check that the winning vendor was not suspended nor debarred from receiving federal funds prior to awarding the contract. Outdoor Recreation Acquisition, Development and Planning – Audit procedures included selection and testing of five competitively procured vendor contracts. • Five out of five vendors tested for procurement did not provide sample support requested to test procurement method selected, price/bid comparison, and cost analysis performed. • Five out of five vendors tested did not provide support for the SAMS verification check that the winning vendor was not suspended nor debarred from receiving federal funds prior to awarding the contract. Questioned costs: Unknown Context: See “Condition.” Cause: The City’s written procurement, suspension and debarment policies and procedures are in compliance with Uniform Grant Guidance but were not properly adhered to. Effect: The City is not in compliance with uniform grant guidance requirements related to procurement, suspension, and debarment. Repeat Finding: Yes. See 2024-005. Recommendation: The City of Nogales should enhance and/or modify existing controls over procurement, suspension and debarment policies and procedures to ensure adherence to all uniform grant guidance requirements. This could include implementing a more robust checklist that should be completed, signed off by management and included with each procurement which has all required items noted such as cost/price analysis and verification of suspension and debarment of vendors. Views of responsible officials: See corrective action plan. Corrective action plan: See corrective action plan.
2024 – 007 Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Department of Interior Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds (ARPA) Outdoor Recreation Acquisition, Development and Planning ALN: 21.027 15.916 Pass-Through Agency: Coronavirus State and Local Fiscal Recovery Funds (ARPA) N/A Outdoor Recreation Acquisition, Development and Planning Arizona State Park Trails Pass-Through Number(s): Coronavirus State and Local Fiscal Recovery Funds (ARPA) N/A Outdoor Recreation Acquisition, Development and Planning 04-007-652304 Award Number and Period: Coronavirus State and Local Fiscal Recovery Funds (ARPA) 1505-0271 3/3/2021 – 12/31/2024 Outdoor Recreation Acquisition, Development and Planning 04/18/2022-12/31/24 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), the City of Nogales must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it 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 the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.324, the non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non- Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by: (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The following is a summary results for each audited program. Coronavirus State and Local Fiscal Recovery Funds (ARPA) - Audit procedures included selection and testing of five competitively procured vendor contracts. Three out of five vendors tested for procurement did not provide support for the procurement method used, price/bid comparison, and cost analysis performed. One out of five vendors tested did not have a valid contract on file. Five out of five vendors tested did not provide support for the SAMS verification check that the winning vendor was not suspended nor debarred from receiving federal funds prior to awarding the contract. Outdoor Recreation Acquisition, Development and Planning – Audit procedures included selection and testing of five competitively procured vendor contracts. • Five out of five vendors tested for procurement did not provide sample support requested to test procurement method selected, price/bid comparison, and cost analysis performed. • Five out of five vendors tested did not provide support for the SAMS verification check that the winning vendor was not suspended nor debarred from receiving federal funds prior to awarding the contract. Questioned costs: Unknown Context: See “Condition.” Cause: The City’s written procurement, suspension and debarment policies and procedures are in compliance with Uniform Grant Guidance but were not properly adhered to. Effect: The City is not in compliance with uniform grant guidance requirements related to procurement, suspension, and debarment. Repeat Finding: Yes. See 2024-005. Recommendation: The City of Nogales should enhance and/or modify existing controls over procurement, suspension and debarment policies and procedures to ensure adherence to all uniform grant guidance requirements. This could include implementing a more robust checklist that should be completed, signed off by management and included with each procurement which has all required items noted such as cost/price analysis and verification of suspension and debarment of vendors. Views of responsible officials: See corrective action plan. Corrective action plan: See corrective action plan.
Assistance Listing, Federal Agency, and Program Name - 21.027 - COVID - 19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - SLFRP0126 Pass through Entity - U.S. Department of Treasury Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR 200.320 and 200.324 outlines the auditee responsibility to utilize the appropriate procurement method and comply with all related requirements of that selected procurement methodology. Also, 2 CFR 180.300 outlines the auditee responsibility related to suspension and debarment requirements for vendors with whom an entity contracts. Condition - The School District did not have sufficient controls in place to ensure compliance with its procurement policy and that appropriate documentation is retained regarding the procurement methodology chosen and support for compliance with the suspension and debarment requirements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the sample of 2 contracts procured this year that we selected for testing, 2 did not have the required support for the procurement method selected based on federal guidelines and the School District's procurement policy. Additionally, the 2 contracts selected for suspension and debarment testing did not have any documentation as it related to suspension and debarment. Cause and Effect - The School District did not retain support to show it obtained price quotes, as required by the small purchases provision; had the appropriate rationale, as required by the noncompetitive solicitation provision; or had support for proposals submitted, as required by the purchases over $250,000 provision. Support was not retained for 2 of the 2 samples selected during procurement testing; therefore, procurement methodology was not supported. Additionally, none of the 2 samples selected for suspension and debarment testing had the required support retained. Recommendation - We recommend the School District implement internal control procedures to ensure that procurement policy is followed and the proper documentation is kept in the procurement files to support any and all procurement decisions in accordance with the purchasing policy and federal regulations. Views of Responsible Officials and Planned Corrective Actions - This finding was due to the District having turnover among key personnel in the grants area, as well as non adherence to policies and procedures related to grant records, grant accounting, and year end close processes. The District will work with the Materials and Procurement department to ensure policies and procedures are updated and staff is trained. Prior to awarding any contract, District staff will search the federal Excluded Parties List System to determine that the contractor is not suspended or debarred. Documentation of this search will be maintained in the grant procurement file.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Criteria: 2 CFR 200.319 states that all procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with Federal procurement standards. 2 CFR 200.214 states in part that recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations. In addition, 2 CFR 200.303 in part states that a recipient of a Federal award must establish, document, and maintain effective internal control over the Federal award. Condition: We have selected and tested three of the largest vendors from the Child Nutrition Cluster for compliance with procurement and suspension and debarment. We identified that one vendor was not properly procured, in accordance with 2 CFR 200.319–2 CFR 200.324. As a result, the District incurred questioned costs in the amount of $31,401.63, which was in excess of $25,000 Federal requirement, based on 2 CFR 200.516. Also, the District did not perform procedures to verify suspension and debarment on the same vendor. Cause: District’s internal controls over procurement in the Child Nutrition Cluster were properly designed but not operating effectively to verify that all vendors are properly procured and verified for suspension and debarment. The District did not properly procure one vendor within the Child Nutrition Cluster that incurred questioned costs in excess of the $25,000 threshold, based on 2 CFR 200.516. Effect: The District did not properly procure one vendor within the Child Nutrition Cluster that incurred questioned costs in excess of the $25,000 threshold, based on 2 CFR 200.516, and, as a result, revealed a significant deficiency in internal controls over procurement in the Child Nutrition Cluster. Repeat Finding: No. Recommendation: We recommend that the District re-evaluate the procurement processes in the Child Nutrition Services program and re-evaluate the design of internal controls over procurement and suspension and debarment to be in compliance with the Federal requirements and the District’s procurement policy.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.