Finding 1100840 (2021-005)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2021
Accepted
2025-02-24
Audit: 343636
Organization: Quileute Tribal School (WA)

AI Summary

  • Core Issue: The School failed to follow its own procurement policies for purchases over $5,000, lacking necessary bidding documentation.
  • Impacted Requirements: Non-compliance with 2 CFR procurement standards and suspension/debarment checks, risking overpayments and engagement with disqualified vendors.
  • Recommended Follow-Up: Ensure adherence to procurement policies, maintain documentation, and implement vendor checks via sam.gov before contracting.

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.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 524394 2021-003
    Material Weakness
  • 524395 2021-003
    Material Weakness
  • 524396 2021-004
    Material Weakness Repeat
  • 524397 2021-005
    Material Weakness Repeat
  • 524398 2021-005
    Material Weakness
  • 524399 2021-006
    Material Weakness
  • 524400 2021-007
    Material Weakness Repeat
  • 1100836 2021-003
    Material Weakness
  • 1100837 2021-003
    Material Weakness
  • 1100838 2021-004
    Material Weakness Repeat
  • 1100839 2021-005
    Material Weakness Repeat
  • 1100841 2021-006
    Material Weakness
  • 1100842 2021-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.042 Indian School Equalization Program $827,317
15.046 Administrative Cost Grants for Indian Schools $456,591
84.027 Special Education Grants to States $449,604
15.047 Indian Education Facilities Operations and Maintenance $297,662
84.425 Covid-19 Bie K-12 Cares Act 2 $148,155
84.010 Title I Grants to Local Educational Agencies $136,120
84.287 21st Century $123,699
84.336 Title II Teacher Quality $90,315
10.559 Summer Food $48,532
15.044 Indian Schools Student Transportation $45,445
84.425 Covid-19 Bie Crrsa (cares 3) $8,910
15.151 Bie- 2019-2020 Enhancement $7,974
84.425 Covid-19 Bie- Geer Funding (cares 1) $7,875
15.062 Replacement and Repair of Indian Schools $-42
15.130 Johnson O'Malley $-1,123