Department of Agriculture, passed through Minnesota Department of Education Federal Financial Assistance Listing/CFDA Number 10.553/10.555 Child Nutrition Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension, and debarment it was identified that there was no review of vendors to ensure that they are not suspended or debarred before purchases are made. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported Context/Sampling - Overall procurement policy. Repeat Finding from Prior Years - No Recommendation - We recommend that management establish a formal process to review vendors before purchases are made to ensure they are not suspended or debarred and are in compliance with the Uniform Guidance and 2 CFR sections 200.318 through 200.326. Views of Responsible Officials - There is no disagreement with the audit finding.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Condition: The Organization has a procurement policy; however, the policy does not include all the elements required by the Uniform Guidance (UG). The policy should detail, among other items, thresholds and procedures for each of the five procurement methods, and how conflicts of interest are identified and addressed. Criteria: 2 CFR section 200.318 through 200.326 outlines the procurement standards and the elements that should be included in the Organization?s policy. Cause: Due to time restraints, the Organization has not yet updated its current policy. Effect: The effect is unknown. Recommendation: We recommend the Organization update its procurement policy with all the elements required by the UG.
Condition: The Organization has a procurement policy; however, the policy does not include all the elements required by the Uniform Guidance (UG). The policy should detail, among other items, thresholds and procedures for each of the five procurement methods, and how conflicts of interest are identified and addressed. Criteria: 2 CFR section 200.318 through 200.326 outlines the procurement standards and the elements that should be included in the Organization?s policy. Cause: Due to time restraints, the Organization has not yet updated its current policy. Effect: The effect is unknown. Recommendation: We recommend the Organization update its procurement policy with all the elements required by the UG.
Condition: The Organization has a procurement policy; however, the policy does not include all the elements required by the Uniform Guidance (UG). The policy should detail, among other items, thresholds and procedures for each of the five procurement methods, and how conflicts of interest are identified and addressed. Criteria: 2 CFR section 200.318 through 200.326 outlines the procurement standards and the elements that should be included in the Organization?s policy. Cause: Due to time restraints, the Organization has not yet updated its current policy. Effect: The effect is unknown. Recommendation: We recommend the Organization update its procurement policy with all the elements required by the UG.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Department of Energy, passed through Colorado Governor's Energy Office, Weatherization Assistance for Low-Income Persons/CFDA Number 81.042 for year ended June 30, 2022 Procurement Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR section 200.320(c), Noncompetitive Procurement, establishes there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can be awarded if the item/service is available only from a single source. Condition: The Organization has a written procurement policy for the year ended June 30, 2022 which established all the requirements of 2 CFR section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), including 2 CFR section 200.320(c), Noncompetitive Procurement; however, documentation of compliance with the policy was not retained for one instance of a single-source vendor for services provided. Cause: In discussing the condition with the Organization?s personnel, the vendor was considered a single source, but proper documentation to this consideration was not maintained. Effect: Noncompliance with the Uniform Guidance could jeopardize future federal funding. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 40 transactions out of 684 total transactions were selected for procurement testing. Repeat Finding from Prior Years: No. Recommendation: The Organization should ensure documentation of compliance with all the requirements of Uniform Guidance, including 2 CFR section 200.320(c), Noncompetitive Procurement. We recommend that the Organization review, approve, and document process for any vendors which would qualify for noncompetitive procurement in the future. Views of Responsible Officials: Management agrees with the finding and will implement changes through a corrective action plan to ensure proper review, approval, and documentation of procurement policy.
2022-009 Prevailing Wage Rate Internal Control and Compliance CFDA Title: ESSER II CFDA Number: 84.425D Federal Award Number: 036-0648-92-2021 Federal Agency: Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: The District did not require a contract indicating the requirement of prevailing wage rate and weekly certified payrolls submitted for federal construction project with contractor. Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141--3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Context: During th testing of expenditures for the ESSER II project we noted construction projects in excess of $2,000. Effect: The District was not in compliance with the prevailing wage rate requirement and the internal control system of the District did not identify the need for the compliance. Cause: Internal control procedures were not in place to ensure a contract was draw up to include the prevailing wage rate clause and to ensure the weekly certified payrolls were submitted to the District. Recommendation: The District should implement internal control procedures for any construction contracts in excess of $2,000 funded with federal monies include a contract with the prevailing wage rate clause and submission of weekly certified payrolls.
2022 ? 006 Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: FY 2021 and FY 2022 Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: H027A190084, H027X210084, H173A180104, H173A210104, H173X10104 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.2 CFR 200.303 states in part: ?The Non-Federal entity must: (e) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: During testing, it was noted that the School did not retain documentation to support compliance with federal procurement standards. Questioned costs: $146,707 Context: For 7 of 7 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Cause: Lack of formal procedures over federal purchase. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation Repeat Finding: The finding is a repeat of a finding in the immediately prior audit report. Prior audit finding number was 2020-005. Recommendation: We recommend that School management establish a system of internal controls to ensure compliance with the grant agreement and procurement requirements of the procurement process. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 006 Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: FY 2021 and FY 2022 Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: H027A190084, H027X210084, H173A180104, H173A210104, H173X10104 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.2 CFR 200.303 states in part: ?The Non-Federal entity must: (e) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: During testing, it was noted that the School did not retain documentation to support compliance with federal procurement standards. Questioned costs: $146,707 Context: For 7 of 7 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Cause: Lack of formal procedures over federal purchase. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation Repeat Finding: The finding is a repeat of a finding in the immediately prior audit report. Prior audit finding number was 2020-005. Recommendation: We recommend that School management establish a system of internal controls to ensure compliance with the grant agreement and procurement requirements of the procurement process. Views of responsible officials: There is no disagreement with the audit finding.
2022-001 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425, 84.425D and 84.425C - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Indiana Department of Education Award Numbers - 2021-2022; S425D200 013; S425U200 13; and S425C200 18 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The School Corporation did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. Questioned Costs: Unknown. "Context: There were multiple construction projects charged to the grant during the year. Three of 23 contractors assigned to these projects were tested and the following was noted: - The School Corporation did not obtain any certified payrolls for the contractor and subcontractors tested." Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The School Corporation was aware of the wage rate requirements as it applied to this grant; however they indicated to contractors and subcontractors that payroll information only need be submitted if requested. The School Corporation did not request this information. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the School Corporation implement a compliance review process over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425, 84.425D and 84.425C - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Indiana Department of Education Award Numbers - 2021-2022; S425D200 013; S425U200 13; and S425C200 18 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The School Corporation did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. Questioned Costs: Unknown. "Context: There were multiple construction projects charged to the grant during the year. Three of 23 contractors assigned to these projects were tested and the following was noted: - The School Corporation did not obtain any certified payrolls for the contractor and subcontractors tested." Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The School Corporation was aware of the wage rate requirements as it applied to this grant; however they indicated to contractors and subcontractors that payroll information only need be submitted if requested. The School Corporation did not request this information. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the School Corporation implement a compliance review process over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425, 84.425D and 84.425C - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Indiana Department of Education Award Numbers - 2021-2022; S425D200 013; S425U200 13; and S425C200 18 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The School Corporation did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. Questioned Costs: Unknown. "Context: There were multiple construction projects charged to the grant during the year. Three of 23 contractors assigned to these projects were tested and the following was noted: - The School Corporation did not obtain any certified payrolls for the contractor and subcontractors tested." Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The School Corporation was aware of the wage rate requirements as it applied to this grant; however they indicated to contractors and subcontractors that payroll information only need be submitted if requested. The School Corporation did not request this information. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the School Corporation implement a compliance review process over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425, 84.425D and 84.425C - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Indiana Department of Education Award Numbers - 2021-2022; S425D200 013; S425U200 13; and S425C200 18 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The School Corporation did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. Questioned Costs: Unknown. "Context: There were multiple construction projects charged to the grant during the year. Three of 23 contractors assigned to these projects were tested and the following was noted: - The School Corporation did not obtain any certified payrolls for the contractor and subcontractors tested." Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The School Corporation was aware of the wage rate requirements as it applied to this grant; however they indicated to contractors and subcontractors that payroll information only need be submitted if requested. The School Corporation did not request this information. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the School Corporation implement a compliance review process over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425, 84.425D and 84.425C - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Indiana Department of Education Award Numbers - 2021-2022; S425D200 013; S425U200 13; and S425C200 18 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The School Corporation did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. Questioned Costs: Unknown. "Context: There were multiple construction projects charged to the grant during the year. Three of 23 contractors assigned to these projects were tested and the following was noted: - The School Corporation did not obtain any certified payrolls for the contractor and subcontractors tested." Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The School Corporation was aware of the wage rate requirements as it applied to this grant; however they indicated to contractors and subcontractors that payroll information only need be submitted if requested. The School Corporation did not request this information. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the School Corporation implement a compliance review process over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
Finding 2022-001: Wage Rate Requirements Program Name: Education Stabilization Fund ? Assistance Listing 84.425D & 84.425U Awarding Agency: U.S. Department of Education, passed through Louisiana Department of Education Finding Type: Material Weakness on Internal Controls over Compliance and Material instance of Non-compliance Questioned Costs: $288,517 for 84.425D and $56,627 for 84.425U. Total questioned cost is $345,144 for the program. Context / Criteria: 2 CFR 200.303(a) requires non-federal entities to establish and maintain internal controls over compliance with federal statutes, laws, and the terms and conditions of grant agreements. 2CFR Part 176, Subpart C requires all laborers and mechanics employed by contractors and subcontractors on projects funded with federal awards to be paid wages at rates not less than those prevailing on projects of a character similar in the locality as determined by the Secretary of Labor in accordance with subchapter IV of Chapter 31 of Title 40, United States Code. This includes a requirement for the contractor to submit to the non-federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: The School District did not have controls in place to ensure construction contracts in excess of $2,000 included provisions for compliance with the Davis-Bacon Act. The School District did not obtain weekly certified payrolls from contractors for each week in which any contract work was performed. Cause / Effect: The School District entered into a contract with a construction manager for a project not funded by federal funds. Subsequent to the effective date of the contract, the School District began to utilize federal funds for payment of the contract. The contract was not amended to comply with the provisions of the Davis-Bacon Act. As a result, the School District was not in compliance with 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326. Recommendation: We recommend management implement procedures to ensure construction contracts entered into that utilize federal funding are reviewed for compliance with federal requirements Views of Responsible Officials and Corrective actions: Management is in agreement with the finding. See accompanying Corrective Action Plan.
Finding 2022-001: Wage Rate Requirements Program Name: Education Stabilization Fund ? Assistance Listing 84.425D & 84.425U Awarding Agency: U.S. Department of Education, passed through Louisiana Department of Education Finding Type: Material Weakness on Internal Controls over Compliance and Material instance of Non-compliance Questioned Costs: $288,517 for 84.425D and $56,627 for 84.425U. Total questioned cost is $345,144 for the program. Context / Criteria: 2 CFR 200.303(a) requires non-federal entities to establish and maintain internal controls over compliance with federal statutes, laws, and the terms and conditions of grant agreements. 2CFR Part 176, Subpart C requires all laborers and mechanics employed by contractors and subcontractors on projects funded with federal awards to be paid wages at rates not less than those prevailing on projects of a character similar in the locality as determined by the Secretary of Labor in accordance with subchapter IV of Chapter 31 of Title 40, United States Code. This includes a requirement for the contractor to submit to the non-federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: The School District did not have controls in place to ensure construction contracts in excess of $2,000 included provisions for compliance with the Davis-Bacon Act. The School District did not obtain weekly certified payrolls from contractors for each week in which any contract work was performed. Cause / Effect: The School District entered into a contract with a construction manager for a project not funded by federal funds. Subsequent to the effective date of the contract, the School District began to utilize federal funds for payment of the contract. The contract was not amended to comply with the provisions of the Davis-Bacon Act. As a result, the School District was not in compliance with 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326. Recommendation: We recommend management implement procedures to ensure construction contracts entered into that utilize federal funding are reviewed for compliance with federal requirements Views of Responsible Officials and Corrective actions: Management is in agreement with the finding. See accompanying Corrective Action Plan.
Finding 2022-001: Wage Rate Requirements Program Name: Education Stabilization Fund ? Assistance Listing 84.425D & 84.425U Awarding Agency: U.S. Department of Education, passed through Louisiana Department of Education Finding Type: Material Weakness on Internal Controls over Compliance and Material instance of Non-compliance Questioned Costs: $288,517 for 84.425D and $56,627 for 84.425U. Total questioned cost is $345,144 for the program. Context / Criteria: 2 CFR 200.303(a) requires non-federal entities to establish and maintain internal controls over compliance with federal statutes, laws, and the terms and conditions of grant agreements. 2CFR Part 176, Subpart C requires all laborers and mechanics employed by contractors and subcontractors on projects funded with federal awards to be paid wages at rates not less than those prevailing on projects of a character similar in the locality as determined by the Secretary of Labor in accordance with subchapter IV of Chapter 31 of Title 40, United States Code. This includes a requirement for the contractor to submit to the non-federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: The School District did not have controls in place to ensure construction contracts in excess of $2,000 included provisions for compliance with the Davis-Bacon Act. The School District did not obtain weekly certified payrolls from contractors for each week in which any contract work was performed. Cause / Effect: The School District entered into a contract with a construction manager for a project not funded by federal funds. Subsequent to the effective date of the contract, the School District began to utilize federal funds for payment of the contract. The contract was not amended to comply with the provisions of the Davis-Bacon Act. As a result, the School District was not in compliance with 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326. Recommendation: We recommend management implement procedures to ensure construction contracts entered into that utilize federal funding are reviewed for compliance with federal requirements Views of Responsible Officials and Corrective actions: Management is in agreement with the finding. See accompanying Corrective Action Plan.
Finding 2022-001: Wage Rate Requirements Program Name: Education Stabilization Fund ? Assistance Listing 84.425D & 84.425U Awarding Agency: U.S. Department of Education, passed through Louisiana Department of Education Finding Type: Material Weakness on Internal Controls over Compliance and Material instance of Non-compliance Questioned Costs: $288,517 for 84.425D and $56,627 for 84.425U. Total questioned cost is $345,144 for the program. Context / Criteria: 2 CFR 200.303(a) requires non-federal entities to establish and maintain internal controls over compliance with federal statutes, laws, and the terms and conditions of grant agreements. 2CFR Part 176, Subpart C requires all laborers and mechanics employed by contractors and subcontractors on projects funded with federal awards to be paid wages at rates not less than those prevailing on projects of a character similar in the locality as determined by the Secretary of Labor in accordance with subchapter IV of Chapter 31 of Title 40, United States Code. This includes a requirement for the contractor to submit to the non-federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: The School District did not have controls in place to ensure construction contracts in excess of $2,000 included provisions for compliance with the Davis-Bacon Act. The School District did not obtain weekly certified payrolls from contractors for each week in which any contract work was performed. Cause / Effect: The School District entered into a contract with a construction manager for a project not funded by federal funds. Subsequent to the effective date of the contract, the School District began to utilize federal funds for payment of the contract. The contract was not amended to comply with the provisions of the Davis-Bacon Act. As a result, the School District was not in compliance with 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326. Recommendation: We recommend management implement procedures to ensure construction contracts entered into that utilize federal funding are reviewed for compliance with federal requirements Views of Responsible Officials and Corrective actions: Management is in agreement with the finding. See accompanying Corrective Action Plan.
Finding 2022-001: Wage Rate Requirements Program Name: Education Stabilization Fund ? Assistance Listing 84.425D & 84.425U Awarding Agency: U.S. Department of Education, passed through Louisiana Department of Education Finding Type: Material Weakness on Internal Controls over Compliance and Material instance of Non-compliance Questioned Costs: $288,517 for 84.425D and $56,627 for 84.425U. Total questioned cost is $345,144 for the program. Context / Criteria: 2 CFR 200.303(a) requires non-federal entities to establish and maintain internal controls over compliance with federal statutes, laws, and the terms and conditions of grant agreements. 2CFR Part 176, Subpart C requires all laborers and mechanics employed by contractors and subcontractors on projects funded with federal awards to be paid wages at rates not less than those prevailing on projects of a character similar in the locality as determined by the Secretary of Labor in accordance with subchapter IV of Chapter 31 of Title 40, United States Code. This includes a requirement for the contractor to submit to the non-federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: The School District did not have controls in place to ensure construction contracts in excess of $2,000 included provisions for compliance with the Davis-Bacon Act. The School District did not obtain weekly certified payrolls from contractors for each week in which any contract work was performed. Cause / Effect: The School District entered into a contract with a construction manager for a project not funded by federal funds. Subsequent to the effective date of the contract, the School District began to utilize federal funds for payment of the contract. The contract was not amended to comply with the provisions of the Davis-Bacon Act. As a result, the School District was not in compliance with 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326. Recommendation: We recommend management implement procedures to ensure construction contracts entered into that utilize federal funding are reviewed for compliance with federal requirements Views of Responsible Officials and Corrective actions: Management is in agreement with the finding. See accompanying Corrective Action Plan.
2022-003 Prevailing Wage Rate Internal Control and Compliance CFDA Title: ESSER II CFDA Number: 84.425D Federal Award Number: 036-0648-92-2021 Federal Agency: U.S. Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: The District did not require a contract indicating the requirement of prevailing wage rate and weekly certified payrolls submitted for federal construction project with contractor. Context: During the testing of expenditures for the ESSER projects we noted construction projects with labor in excess of $2,000. Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141--3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Effect: The District was not in compliance with the prevailing wage rate requirement and the internal control system of the District did not identify the need for the compliance. Cause: Internal control procedures were not in place to ensure a contract was draw up to include the prevailing wage rate clause and to ensure the weekly certified payrolls were submitted to the District. Recommendation: The District should implement internal control procedures for any construction contracts in excess of $2,000 funded with federal monies include a contract with the prevailing wage rate clause and submission of weekly certified payrolls.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
Finding Number: 2022-003 Repeat Finding: Similar to prior year finding 2021-002 Program Name/Assistance Listing Title: Indian School Equalization Program, Special Education Cluster Assistance Listing Number: 15.042, 84.027 Federal Agency: U.S. Department of the Interior, U.S. Department of Education Federal Award Number: A19AV00847 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Procurement, Suspension and Debarment Criteria: Under 2 CFR ?215.43 the School is required to implement certain procurement policies that adhere to the minimum federal requirements as outlined in 2 CFR ?215.44. Non-federal entities other than States, including those operating federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the Procurement requirements identified in 2 CFR part 200. Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?80.220. Condition: The School did not always follow procurement standards as put forth in 2 CFR ?200.318 through ?200.326. In addition, the School did not verify that covered transactions were made only to entities that were not suspended or debarred or otherwise excluded. Effect: Noncompliance with federal regulation that led to a qualified audit opinion over the listed federal programs as noted above. Cause: Management oversight. Context: For two of 2 vendors in the Formal Procurement Threshold reviewed, the School did not maintain documentation that appropriate procurement procedures were performed. Additionally, for twenty-four of 29 vendors within the Simplified Acquisition Threshold reviewed, the School did not maintain documentation that appropriate procurement procedures were performed. Finally, for four of 21 vendors with at least $25,000 in purchases reviewed, the School did not maintain documentation that a current suspension and debarment check was performed. Recommendation: The School should review its procurement procedures to ensure that proper procurement procedures are performed documentation is maintained to support the procurement. Response: The School concurs with this recommendation and will implement procedures to ensure compliance with federal regulation. Contact person: Dolores Baluyut, Business Manager
Finding Number: 2022-003 Repeat Finding: Similar to prior year finding 2021-002 Program Name/Assistance Listing Title: Indian School Equalization Program, Special Education Cluster Assistance Listing Number: 15.042, 84.027 Federal Agency: U.S. Department of the Interior, U.S. Department of Education Federal Award Number: A19AV00847 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Procurement, Suspension and Debarment Criteria: Under 2 CFR ?215.43 the School is required to implement certain procurement policies that adhere to the minimum federal requirements as outlined in 2 CFR ?215.44. Non-federal entities other than States, including those operating federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the Procurement requirements identified in 2 CFR part 200. Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?80.220. Condition: The School did not always follow procurement standards as put forth in 2 CFR ?200.318 through ?200.326. In addition, the School did not verify that covered transactions were made only to entities that were not suspended or debarred or otherwise excluded. Effect: Noncompliance with federal regulation that led to a qualified audit opinion over the listed federal programs as noted above. Cause: Management oversight. Context: For two of 2 vendors in the Formal Procurement Threshold reviewed, the School did not maintain documentation that appropriate procurement procedures were performed. Additionally, for twenty-four of 29 vendors within the Simplified Acquisition Threshold reviewed, the School did not maintain documentation that appropriate procurement procedures were performed. Finally, for four of 21 vendors with at least $25,000 in purchases reviewed, the School did not maintain documentation that a current suspension and debarment check was performed. Recommendation: The School should review its procurement procedures to ensure that proper procurement procedures are performed documentation is maintained to support the procurement. Response: The School concurs with this recommendation and will implement procedures to ensure compliance with federal regulation. Contact person: Dolores Baluyut, Business Manager
2022-005 Federal Agency: Department of the Treasury and Federal Communications Commission Federal Program Name: American Rescue Plan Act and Emergency Connectivity Fund Program Assistance Listing Number: 21.027 and 32.009 Federal Award Identification Number and Year: 12060-OPM20600-29669 and ECF202108044 Pass-Through Agency: Office of Policy and Management Pass-Through Number(s): N/A Award Period: 7/1/2021 - 6/30/2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow Uniform Guidance and was in compliance with the major program. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: N/A - First year audited as a major program. Recommendation: We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding and is in process of developing a formal policy
2022-006 Federal Agency: Department of the Treasury and Federal Communications Commission Federal Program Name: American Rescue Plan Act and Emergency Connectivity Fund Program Assistance Listing Number: 21.027 and 32.009 Federal Award Identification Number and Year: 12060-OPM20600-29669 and ECF202108044 Pass-Through Agency: Office of Policy and Management Pass-Through Number(s): N/A Award Period: 7/1/2021 - 6/30/2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of suspension, and debarment. Condition: The Town must update their policies to indicate they will verify that an entity with which they plan to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow Uniform Guidance and was in compliance with the major program. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it related to suspension & debarment. Repeat Finding: N/A - First year audited as a major program. Recommendation: We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding and is in process of developing a formal policy.
2022-005 Federal Agency: Department of the Treasury and Federal Communications Commission Federal Program Name: American Rescue Plan Act and Emergency Connectivity Fund Program Assistance Listing Number: 21.027 and 32.009 Federal Award Identification Number and Year: 12060-OPM20600-29669 and ECF202108044 Pass-Through Agency: Office of Policy and Management Pass-Through Number(s): N/A Award Period: 7/1/2021 - 6/30/2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow Uniform Guidance and was in compliance with the major program. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: N/A - First year audited as a major program. Recommendation: We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding and is in process of developing a formal policy
2022-006 Federal Agency: Department of the Treasury and Federal Communications Commission Federal Program Name: American Rescue Plan Act and Emergency Connectivity Fund Program Assistance Listing Number: 21.027 and 32.009 Federal Award Identification Number and Year: 12060-OPM20600-29669 and ECF202108044 Pass-Through Agency: Office of Policy and Management Pass-Through Number(s): N/A Award Period: 7/1/2021 - 6/30/2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of suspension, and debarment. Condition: The Town must update their policies to indicate they will verify that an entity with which they plan to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow Uniform Guidance and was in compliance with the major program. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it related to suspension & debarment. Repeat Finding: N/A - First year audited as a major program. Recommendation: We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding and is in process of developing a formal policy.
Finding No. 2022-002 Education Stabilization Fund: U.S. Department of Education: COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Aid Portion, Assistance Listing 84.425F (award number P425F204328) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement ? Procurement ? Significant Deficiency and Noncompliance Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). For those procurements supported by HEERF grant funds, auditors should determine if institutions sufficiently documented rationales and determinations in making any sole source awards during the time of national emergency due to the coronavirus. Exceptions from the competitive procurement requirements of the Uniform Guidance may be accepted if institutions have documented that the public exigency or emergency would not permit a delay, in accordance with 2 CFR section 200.320(f)(2). A circumstance that may influence this determination is the length of time between the procurements and the emergency at issue. Specifically, exceptions are more likely to be acceptable the closer the procurement occurred to the March 13, 2020 declaration of the national emergency. Further, the non-Federal entity must establish and maintain an 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 terms and conditions of the Federal award (2 CFR 200.303). Condition and Context The University?s procurement policy for procurements over $10,000 is to either competitively bid it or document the sole source justification for why competitive bidding was not able to be completed. Based on our test work, for two of our seven selections, the University did not properly document its compliance with the procurement policy. For one selection, we noted that the University did not properly retain documentation for the competitive bidding, while for the other selection, the University did not properly document within the vendor?s procurement file that it was sole sourced due to the pandemic and needing the services in an expedited fashion as allowed per the HEERF requirements. Cause The documentation of procurement decisions was not properly retained to support the decisions made during the time period. Effect The University was not in compliance with their procurement policy. Questioned Costs There were no questioned costs identified as the University contracted with the respective parties in both cases and the costs were allowable under the HEERF requirements. Recommendation The University should strengthen its policies and practices to ensure that documentation is retained for all procurement decisions in order to support compliance with their procurement policy. Views of Responsible Official Management agrees with the recommendation. The University will ensure that all procurement decisions comply with the Stevens Procurement Policy and are properly documented, including the procurement method used (e.g., competitive bidding or sole source justification). The Director of Procurement will ensure that all Stevens employees responsible for making purchasing decisions at the University are familiar with the Procurement Policy and the need to ensure full compliance even when making purchasing decisions during emergency situations (e.g., COVID pandemic). The Director of Procurement will ensure compliance with the Stevens Procurement Policy.
2022 ? 006 Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: FY 2021 and FY 2022 Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: H027A190084, H027X210084, H173A180104, H173A210104, H173X10104 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.2 CFR 200.303 states in part: ?The Non-Federal entity must: (e) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: During testing, it was noted that the School did not retain documentation to support compliance with federal procurement standards. Questioned costs: $146,707 Context: For 7 of 7 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Cause: Lack of formal procedures over federal purchase. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation Repeat Finding: The finding is a repeat of a finding in the immediately prior audit report. Prior audit finding number was 2020-005. Recommendation: We recommend that School management establish a system of internal controls to ensure compliance with the grant agreement and procurement requirements of the procurement process. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 006 Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: FY 2021 and FY 2022 Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: H027A190084, H027X210084, H173A180104, H173A210104, H173X10104 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.2 CFR 200.303 states in part: ?The Non-Federal entity must: (e) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: During testing, it was noted that the School did not retain documentation to support compliance with federal procurement standards. Questioned costs: $146,707 Context: For 7 of 7 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Cause: Lack of formal procedures over federal purchase. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation Repeat Finding: The finding is a repeat of a finding in the immediately prior audit report. Prior audit finding number was 2020-005. Recommendation: We recommend that School management establish a system of internal controls to ensure compliance with the grant agreement and procurement requirements of the procurement process. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 006 Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: FY 2021 and FY 2022 Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: H027A190084, H027X210084, H173A180104, H173A210104, H173X10104 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.2 CFR 200.303 states in part: ?The Non-Federal entity must: (e) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: During testing, it was noted that the School did not retain documentation to support compliance with federal procurement standards. Questioned costs: $146,707 Context: For 7 of 7 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Cause: Lack of formal procedures over federal purchase. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation Repeat Finding: The finding is a repeat of a finding in the immediately prior audit report. Prior audit finding number was 2020-005. Recommendation: We recommend that School management establish a system of internal controls to ensure compliance with the grant agreement and procurement requirements of the procurement process. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 006 Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: FY 2021 and FY 2022 Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: H027A190084, H027X210084, H173A180104, H173A210104, H173X10104 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.2 CFR 200.303 states in part: ?The Non-Federal entity must: (e) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: During testing, it was noted that the School did not retain documentation to support compliance with federal procurement standards. Questioned costs: $146,707 Context: For 7 of 7 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Cause: Lack of formal procedures over federal purchase. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation Repeat Finding: The finding is a repeat of a finding in the immediately prior audit report. Prior audit finding number was 2020-005. Recommendation: We recommend that School management establish a system of internal controls to ensure compliance with the grant agreement and procurement requirements of the procurement process. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 006 Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: FY 2021 and FY 2022 Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: H027A190084, H027X210084, H173A180104, H173A210104, H173X10104 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.2 CFR 200.303 states in part: ?The Non-Federal entity must: (e) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: During testing, it was noted that the School did not retain documentation to support compliance with federal procurement standards. Questioned costs: $146,707 Context: For 7 of 7 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Cause: Lack of formal procedures over federal purchase. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation Repeat Finding: The finding is a repeat of a finding in the immediately prior audit report. Prior audit finding number was 2020-005. Recommendation: We recommend that School management establish a system of internal controls to ensure compliance with the grant agreement and procurement requirements of the procurement process. Views of responsible officials: There is no disagreement with the audit finding.