Finding Text
Program Information:
U.S. Department of the Interior
AL # Award Number Award Period Program Name
15.042 A19AV00888 7/1/2020-6/30/2021 Indian School Equalization Program
15.046 A19AV00888 7/1/2020-6/30/2021 Administrative Cost Grants for Indian Schools
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.
During the review of the School’s procurement policies, the following was noted:
• Any purchase of materials, supplies, or equipment having a purchase price exceeding $5,000 shall
be purchased only after having requested at least three bids or as needed, advertised for sealed bids
for a period of not less than five (5) days.
Non-Federal entities other than States, including those operating Federal programs as
subrecipients of States, must follow the suspension and 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.
2 CFR § 200.303 - Internal controls states, the recipient and subrecipient must:
Establish and maintain effective internal control over the Federal award that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the
Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: During the testing of 15.042, the following was noted:
• 1 of 1 Individually Important Items tested did not have bidding documentation or sole source
justification.
• 1 of 1 samples tested did not have bidding documentation or sole source justification.
During the testing of 15.046, the following was noted:
• 2 of 2 Individually Important Items and 2 of 2 procurement samples did not have bidding
documentation or sole source justification.
• 1 of 1 Individually Important Items and 1 of 1 suspension and debarment samples did not have
verification that a suspension and debarment search was performed.
[ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness
Cause: The School was not following its policies for purchases that exceed $5,000. For suspension and
debarment, there were ineffective controls in place during the period, along with management oversight.
Effect: The School could be overpaying for services or items that could be obtained elsewhere for less.
The School could also be engaging with vendors who are suspended or debarred.
Questioned Costs:
Procurement: 15.042 – None reported as known and likely questioned costs did not exceed
$25,000; 15.046 – Known – $75,425.
Suspension and debarment: 15.042 and 15.046 – no questioned costs.
Repeat Finding: Procurement – Yes, 2020-002 for 15.042; Suspension and Debarment – No
Recommendation: We recommend that the School follow its written procurement policies and maintain
proper supporting documentation. Additionally, we recommend the School develop procedures to ensure
that before contracting with a vendor, a search is performed on https://www.sam.gov, a screen print of the
search results is performed, and the results filed in the vendor’s file.
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.