Finding 1106741 (2024-004)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-26
Audit: 348381
Organization: School City of Hobart (IN)

AI Summary

  • Core Issue: The School Corporation failed to provide adequate oversight of the Northwest Indiana Special Education Cooperative, leading to noncompliance with federal procurement requirements.
  • Impacted Requirements: The Cooperative did not follow formal procurement methods for expenditures exceeding the Indiana threshold of $150,000, resulting in a material weakness.
  • Recommended Follow-Up: Implement internal controls and training to ensure compliance with procurement procedures for federal funds, particularly for expenditures above the Simplified Acquisition Threshold.

Finding Text

FINDING 2024-004 Subject: Special Education Cluster (IDEA) - Procurement Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-ARP, 23611-043-PN01, 24611-043-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 21 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) When the value of the procurement for property or services exceeds the simplified acquisition threshold (SAT), or a lower threshold established by a nonfederal entity, formal procurement methods are required. The SAT is typically set at $250,000; however, Indiana Code 5-22-8 has a more restrictive threshold, and, therefore, the SAT threshold is set at $150,000. Formal procurement methods require adherence to documented procedures and formal methods such as sealed bids or proposals. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with procurement requirements. The Cooperative did not have procedures in place to ensure compliance with procurements in excess of the SAT threshold. During 2023-2024, the Cooperative had three vendors which exceeded the SAT, and all three vendors were tested. The Cooperative did not obtain sealed bids or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. The total dollar amount spent with all three vendors was $1,417,349. The lack of internal controls and noncompliance were systemic issues limited to 2023-2024. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance awards exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: . . . INDIANA STATE BOARD OF ACCOUNTS 22 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. . . . (2) Proposals. A procurement method in which either a fixed price or costreimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." Cause The Cooperative noted they were unaware of the procurement requirements of expenditures exceeding the Simplified Acquisition Threshold. They stated they have used the same vendors to provide professional services for several years but only recently started using federal grant award funds for the services. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the vendors paid with federal award funds by the Cooperative are procured using the required methods. Without following the required methods for procurement, the Cooperative could be overpaying for services. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require that appropriate procurement methods are used by the Cooperative for vendors that exceed the Simplified Acquisition Threshold. Appropriate documentation should be maintained to ensure the procurement methods are being followed and compliance with Procurement methods are being followed. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 530291 2024-003
    Significant Deficiency
  • 530292 2024-003
    Significant Deficiency
  • 530293 2024-003
    Significant Deficiency
  • 530294 2024-003
    Significant Deficiency
  • 530295 2024-003
    Significant Deficiency
  • 530296 2024-004
    Material Weakness
  • 530297 2024-004
    Material Weakness
  • 530298 2024-004
    Material Weakness
  • 530299 2024-004
    Material Weakness
  • 530300 2024-005
    Material Weakness Repeat
  • 530301 2024-005
    Material Weakness Repeat
  • 1106733 2024-003
    Significant Deficiency
  • 1106734 2024-003
    Significant Deficiency
  • 1106735 2024-003
    Significant Deficiency
  • 1106736 2024-003
    Significant Deficiency
  • 1106737 2024-003
    Significant Deficiency
  • 1106738 2024-004
    Material Weakness
  • 1106739 2024-004
    Material Weakness
  • 1106740 2024-004
    Material Weakness
  • 1106742 2024-005
    Material Weakness Repeat
  • 1106743 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $2.03M
84.425 Education Stabilization Fund 2023 $1.87M
10.555 National School Lunch Program 2024 $1.30M
84.027 Special Education Grants to States 2024 $1.16M
84.027 Special Education Grants to States 2023 $749,184
84.010 Title I Grants to Local Educational Agencies 2023 $747,880
84.010 Title I Grants to Local Educational Agencies 2024 $539,393
10.553 School Breakfast Program 2023 $386,417
10.553 School Breakfast Program 2024 $315,820
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2023 $239,308
84.425 Education Stabilization Fund 2024 $224,025
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $210,032
93.778 Medical Assistance Program 2024 $114,352
11.419 Coastal Zone Management Administration Awards 2023 $87,795
10.559 Summer Food Service Program for Children 2024 $69,452
93.778 Medical Assistance Program 2023 $68,773
84.424 Student Support and Academic Enrichment Program 2024 $64,884
10.559 Summer Food Service Program for Children 2023 $39,727
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $34,322
84.424 Student Support and Academic Enrichment Program 2023 $33,343
84.173 Special Education Preschool Grants 2024 $22,474
84.173 Special Education Preschool Grants 2023 $18,372
10.649 Pandemic Ebt Administrative Costs 2023 $3,135