Finding 1123733 (2024-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls for procurement and verifying contractor eligibility, leading to repeated compliance failures.
  • Impacted Requirements: Noncompliance with federal procurement standards and suspension/debarment verification as outlined in 2 CFR 200 regulations.
  • Recommended Follow-Up: Implement a robust internal control system to ensure proper procurement procedures and contractor verification are consistently followed.

Finding Text

FINDING 2024-004 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY22-23, FY23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-001. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and the Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. The informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not have effective controls in place to ensure that an adequate number of price or rate quotations were obtained for all small purchases. The School Corporation did not obtain price or rate quotations from an adequate number of sources for all three vendors that were tested that met the small purchase threshold. Suspension and Debarment Prior to entering into subawards and covered transactions with the Child Nutrition Cluster (CNC) award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transactions with that vendor. The School Corporation did not have effective controls in place to ensure that the verification was completed for all contractors prior to entering into covered transactions. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 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: . . . (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . . Cause Management had not established a system of internal controls to ensure documentation was obtained and retained to demonstrate they had properly procured all small purchases. Management had not established a system of internal controls to ensure that the School Corporation's procedures for verifying a contractor's suspension and debarment status was followed for all contractors. Effect Without a proper design or implementation of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. This could result in the School Corporation overpaying for goods or services or paying a contractor who has been suspended or debarred, which would be unallowable. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management strengthen its system of internal controls to ensure that an adequate number of price or rate quotations are obtained for all small purchases and that suspension and debarment is verified for all covered transaction of $25,000 or more. 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 Subrecipient Monitoring

Other Findings in this Audit

  • 547290 2024-003
    Material Weakness
  • 547291 2024-004
    Material Weakness Repeat
  • 547292 2024-003
    Material Weakness
  • 547293 2024-004
    Material Weakness Repeat
  • 547294 2024-003
    Material Weakness
  • 547295 2024-004
    Material Weakness Repeat
  • 547296 2024-003
    Material Weakness
  • 547297 2024-004
    Material Weakness Repeat
  • 547298 2024-002
    Material Weakness
  • 547299 2024-002
    Material Weakness
  • 547300 2024-002
    Material Weakness
  • 547301 2024-002
    Material Weakness
  • 1123732 2024-003
    Material Weakness
  • 1123734 2024-003
    Material Weakness
  • 1123735 2024-004
    Material Weakness Repeat
  • 1123736 2024-003
    Material Weakness
  • 1123737 2024-004
    Material Weakness Repeat
  • 1123738 2024-003
    Material Weakness
  • 1123739 2024-004
    Material Weakness Repeat
  • 1123740 2024-002
    Material Weakness
  • 1123741 2024-002
    Material Weakness
  • 1123742 2024-002
    Material Weakness
  • 1123743 2024-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $346,236
10.555 National School Lunch Program 2024 $258,575
84.425 Education Stabilization Fund 2024 $239,380
84.010 Title I Grants to Local Educational Agencies 2024 $172,152
84.010 Title I Grants to Local Educational Agencies 2023 $125,903
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response 2023 $100,000
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response 2024 $100,000
10.553 School Breakfast Program 2023 $75,459
84.425 Education Stabilization Fund 2023 $61,407
10.553 School Breakfast Program 2024 $60,119
84.411 Education Innovation and Research (formerly Investing in Innovation (i3) Fund) 2023 $39,644
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $33,967
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $26,028
84.411 Education Innovation and Research (formerly Investing in Innovation (i3) Fund) 2024 $24,337
84.424 Student Support and Academic Enrichment Program 2023 $20,000
84.027 Special Education Grants to States 2023 $14,079
84.424 Student Support and Academic Enrichment Program 2024 $10,573
84.287 Twenty-First Century Community Learning Centers 2023 $3,614
84.027 Special Education Grants to States 2024 $461