Finding Text
Finding No. 2023-004 Suspension and Debarment
Federal Agency: U.S. Department of Education; U.S. Department of the Treasury
Federal Program Name: Special Education Cluster (IDEA); Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 84.027/84.173; 21.027
Federal Award Identification Number and Year: H027A220054 – 2023; SLFRP4547 – 2021
Pass-Through Agency: RI Department of Elementary and Secondary Education, RI Department of Revenue
Pass-Through Number(s): 2725-13202-301; 12060-OPM20600-29669
Award Period: 7/1/22-6/30/23; 3/3/21-12/31/24
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement
Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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).
Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by:
(a) Checking SAM (System for Award Management) Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person
Condition
The Town and Coventry Public Schools do not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred.
Questioned Costs
None
Context
Although the Town and Coventry Public Schools do not have policies or procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred, we did not identify instances where Federal grant awards were paid to suspended or debarred vendors for 8 of 8 suspension and debarment transactions selected for testing.
Cause
Management was not aware of the requirements of 2 CFR section 180 within Uniform Guidance.
Effect
The Town and Coventry Public Schools are at risk for noncompliance with federal grants as it relates to suspension and debarment.
Repeat Finding
Yes, repeat of prior year finding 2022-008.
Recommendation
We recommend that the Town and Coventry Public Schools implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods or services.
Views of Responsible Officials
Management agrees with this finding.