Finding Text
Finding Number: 2024-002
Repeat Finding: Yes, 2023-002, 2022-002
Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs:
Indian School Equalization 15.042 A23AV00813 N/A
Administrative Cost Grants for Indian Schools 15.046 A23AV00813 N/A
Federal Agency(ies): U.S. Department of Interior
Pass-Through Agency(ies): Bureau of Indian Education
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirements: Procurement and Suspension and Debarment
Criteria
Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320.
Condition
Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold.
Cause
The School’s internal controls over procurement of goods and services were not adequate.
Effect
The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement.
Context
The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to two vendors with the Indian School Equalization Program and four vendors with the Administrative Cost Grants for Indian Schools. Additionally, for three non-cooperative-purchase vendors paid in excess of the small purchase threshold ($10,000), the School did not prepare and maintain documentation for at least 3 written quotes from qualified sources, one instance from the Indian School Equalization Program and two instances from the Administrative Cost Grants for Indian Schools. The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements.
Views of Responsible Officials
See Corrective Action Plan.