Finding Text
Procurement, Suspension and Debarment (Repeat Finding 2023-009)
U.S. Department of Education/Passed Through Opportunity 180
Assistance Listing Number 84.282B – Charter Schools Program (CSP) – Grants for the
Opening of New Charter Schools
Award Number S282A200009-20A
Subgrantee Number CSP-2021-08655
Award Date – 4/1/21 to 8/31/23
Criteria – Management is responsible for implementing internal controls related to
Procurement, Suspension and Debarment, as required by the Uniform Guidance.
Condition – Evidence of review and approval of the bids/quotes obtained and of the verification
that the vendor was not suspended or debarred, prior to entering into a transaction with the
vendor, could not be provided for one vendor tested.
Questioned Costs – None
Context/Sampling – A non-statistical sample of one vendor out of four was selected for testing.
Cause – The School lacked sufficient internal controls to ensure that the review and approval
of bids/quotes and the verification that the vendor was not suspended or debarred occurred
and was documented prior to the expenditure.
Effect or Potential Effect – There is a risk that the School could enter into a transaction with a
vendor without proper approval, or with a vendor who is suspended or debarred.
Recommendation – We recommend the School thoroughly document the review and approval
process for all procurements to ensure compliance with Uniform Guidance. Additionally, we
recommend maintaining records that confirm vendors have been verified as not being
suspended or debarred prior to engaging in any transactions. The School can further include
a clause in vendor contracts or obtain a certification from vendors to this effect.
Views of Responsible Officials and Planned Corrective Actions – These findings were for
purchases prior to the new School principal coming on board. Upon hiring in April 2024, the new
principal was fully trained in School internal control policies. In addition, on July 1, 2024, a
process was put in place to maintain evidence of verification of suspension and debarment with
SAM.gov for all required vendors.