Finding Text
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐001
Repeat Finding: No
Program Name/Assistance Listing Title: Education Stabilization Fund
Assistance Listing Number: 84.425U
Federal Agency: U.S. Department of Education
Federal Award Number: 21528001075902
Pass‐Through Agency: Texas Education Agency
Questioned Costs: N/A
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirement: Procurement and 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. Additionally, non‐federal entities are
prohibited from contracting with or making subawards under covered transactions to parties that are
suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity
at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and
agency adopting regulations, is not suspended or debarred or otherwise excluded from participating
in the transaction. This verification may be accomplished by (1) checking the System of Award
Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a
certification from the entity, or adding a clause or condition to the covered transaction with that
entity (2 CFR §180.300).
Condition
The District did not follow Federal, State, and Board policies and regulations governing procurement.
Cause
The District official responsible for making the purchase was not aware of the procurement
compliance requirements. Additionally, those responsible for approving the purchase did not verify
compliance.
Effect
The District was not in compliance with Federal, State, and Board policies and regulations governing
procurement.
Context
The District procured computers, software licenses, and charging carts in the amount of $356,747
using quotations rather than issuing a formal procurement. Furthermore, the District did not check
whether the vendor was suspended or debarred.
Recommendation
District employees who are delegated the authority to procure goods and services should receive
training on Federal, State, and Board procurement policies and procedures. Additionally, approvers
of requisitions should ensure purchases exceeding the formal procurement threshold are
appropriately procured in accordance with Federal, State and Board policies and regulations.
Views of Responsible Officials
See Corrective Action Plan.