Finding Text
Finding Number: 2024‐004
Repeat Finding: Yes, 2023‐002
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A23AV00840 n/a
Indian School Student Transportation 15.044 A23AV00840 n/a
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Procurement and Suspension and Debarment
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 §§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.
Condition
The School had adopted procurement policies mandated under 2 CFR §215.43, but did not perform
some of the procedures outlined for purchases.
Cause
Proper documentation was not obtained or maintained by the School. The School has not
implemented controls to perform the collection of quotes, suspension and debarment checks for
vendors, and maintaining conflict of interest files.
Effect
The School was not always in compliance with Board adopted policies and federal regulations and
guidelines.
Context
The sample was not intended to be, and was not, a statistically valid sample. During our review of
disbursements, we noted the following:
The School did not maintain suspension and debarment for purchases over $25,000 during the
year.
For three of five purchases reviewed in the written quote range, written quotes for purchases
over $2,500 were not obtained.
For three sealed proposals reviewed, the District did not maintain documentation.
For one of five purchases reviewed in the written quote range, the expenditure was not
reviewed/approved by an authorized person prior to the purchase date. Recommendation
The School should follow its adopted procurement procedures to ensure full and open competition
among prospective vendors and adherence to federal rules and regulations.
Views of Responsible Officials
See Corrective Action Plan.