Finding Text
2022-004 – Procurement, Suspension, and Debarment
Federal Program Information
Funding Agency: US Department of Education
Title: Special Education Cluster
AL Number: 84.027; 84.173
Criteria
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. Furthermore, Non-federal entities
are prohibited from contracting with or making subawards under covered transactions to
parties that are suspended or debarred. “Covered transactions” include contracts for
goods and services awarded under a non-procurement transaction that are expected to
equal or exceed $25,000.
Condition
Upper Valley Special Education District does not have a written procurement policy in
place that follows Uniform Guidance. In addition, the District is not reviewing applicable
vendors for suspension and debarment.
Questioned Costs
None.
Context
During inquiry and testing we noted that UVSE did not have a procurement policy in place
that follows Uniform Guidance and that they do not ensure vendors are not suspended or
debarred from receiving federal funds.
Effect
Upper Valley Special Education District is not in compliance with Uniform Guidance
procurement, suspension, and procurement requirements. Also, the District has an
increased risk of entering into a covered transaction with a vendor who is suspended or
debarred from receiving federal funds.
Cause
Management oversight.
Recommendation
The District’s should create and implement a procurement policy that follows federal
requirements. The District should also create policies and procedures to ensure they do
not enter into a covered transaction with a vendor who is suspended or debarred from
receiving federal funds.
Repeat Finding
This is not a repeat finding.
Views of Responsible Officials
See corrective action plan.