Finding 1137010 (2023-004)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2025-05-16
Audit: 356492
Organization: Town of Coventry, Rhode Island (RI)

AI Summary

  • Core Issue: The Town and Coventry Public Schools lack policies to prevent contracting with suspended or debarred parties, risking noncompliance with federal regulations.
  • Impacted Requirements: Compliance with 2 CFR 200.213 and 2 CFR 180.300, which mandate checks on vendor eligibility for federal assistance programs.
  • Recommended Follow-Up: Implement policies and procedures to verify vendor suspension or debarment status before entering contracts or subawards.

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.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility Significant Deficiency

Other Findings in this Audit

  • 560563 2023-003
    Significant Deficiency Repeat
  • 560564 2023-003
    Significant Deficiency Repeat
  • 560565 2023-003
    Significant Deficiency Repeat
  • 560566 2023-004
    Significant Deficiency Repeat
  • 560567 2023-004
    Significant Deficiency Repeat
  • 560568 2023-004
    Significant Deficiency Repeat
  • 560569 2023-005
    Significant Deficiency
  • 1137005 2023-003
    Significant Deficiency Repeat
  • 1137006 2023-003
    Significant Deficiency Repeat
  • 1137007 2023-003
    Significant Deficiency Repeat
  • 1137008 2023-004
    Significant Deficiency Repeat
  • 1137009 2023-004
    Significant Deficiency Repeat
  • 1137011 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $4.35M
84.027 Special Education Grants to States $1.70M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.60M
10.559 Summer Food Service Program for Children $966,153
84.010 Title I Grants to Local Educational Agencies $813,309
93.434 Every Student Succeeds Act/preschool Development Grants $341,311
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $255,413
84.371 Comprehensive Literacy Development $190,829
10.555 National School Lunch Program $181,871
84.173 Special Education Preschool Grants $52,380
84.424 Student Support and Academic Enrichment Program $30,000
10.582 Fresh Fruit and Vegetable Program $19,272
20.616 National Priority Safety Programs $13,746
21.016 Equitable Sharing $10,794
10.579 Child Nutrition Discretionary Grants Limited Availability $10,000
16.607 Bulletproof Vest Partnership Program $8,788
84.048 Career and Technical Education -- Basic Grants to States $8,611
97.042 Emergency Management Performance Grants $4,096
84.031 Higher Education Institutional Aid $3,498
93.069 Public Health Emergency Preparedness $649