Finding Text
2024-001- Updated Procurement Policy
Federal Agency: U.S. Department of Education
Award Name: Charter Schools
Program Year: 2024
Assistance Listing Number: 84.282
Compliance: Procurement and Suspension and Debarment
Finding Type: Significant deficiency in internal control over compliance
Criteria: Management is responsible for having a bid process for contracts entered into with federal funds.
It was noted that the School does have a process, however, it is outdated and should be more in line with
the federal procurement process.
Condition and context: During procurement testing, it was noted that the policy had significantly lower
thresholds for procuring contracts than the federal procurement policy.
Cause of condition: The School received a large, one-time, federal grant in the prior year. Prior to this the
School rarely received any large dollar federal grants. The School had previously never had a need to go
through a bid process.
Effect of condition: As a result of this condition, the School has a significantly lower threshold than federal
standards requires. Although they were in compliance with federal regulations, the School did not follow
their set policy for the bid process.
Recommendation: It is recommended that the School update their procurement policy to match the federal
policy.
View of Responsible Officials and Planned Corrective Action:
Spark Academy acknowledges that the existing procurement policy contains thresholds significantly lower
than the federal procurement standards and has not been updated to reflect the level of federal funding
currently received.
To correct this issue, the following actions will be taken:
1. Procurement Policy Revision: The procurement policy will be fully revised to incorporate the
current federal procurement standards as outlined in 2 CFR Part 200, including appropriate micropurchase,
small purchase, and formal procurement thresholds.
2. Board Approval: The updated procurement policy will be presented to the Board of Trustees for
review and formal approval.
3. Training and Implementation: Staff responsible for federal purchasing will receive training on the
revised procurement policy to ensure full understanding and compliance.
4. Ongoing Monitoring: Management will conduct periodic internal reviews of procurement
activities to verify adherence to the updated policy.
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Planned Implementation Date of Corrective Action: September 30, 2025
Person Responsible for Corrective Action: Business Manager