Finding 1153125 (2024-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-16

AI Summary

  • Core Issue: The School failed to consistently follow federal procurement standards, leading to noncompliance.
  • Impacted Requirements: Compliance with 2 CFR §§200.318 through 200.326 is necessary for all procurement activities.
  • Recommended Follow-up: The School should review and enhance its procurement procedures to ensure proper documentation and compliance.

Finding Text

Finding Number: 2024-002 Repeat Finding: Similar to prior year finding 2023-003 Program Name/Assistance Listing Title: Indian School Equalization, Special Education Cluster Assistance Listing Number: 15.042, 84.027 Federal Agency: U.S. Department of the Interior, U.S. Department of Education Federal Award Number: A23AV00811 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Procurement, Suspension and Debarment Criteria: Under 2 CFR §215.43 the School is required to implement certain procurement policies that adhere to the minimum federal requirements as outlined in 2 CFR §215.44. 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 did not always follow procurement standards as put forth in 2 CFR §200.318 through §200.326. Effect: Noncompliance with federal regulation that led to a qualified audit opinion over the listed federal programs as noted above. Cause: Management oversight. Context: For two of 25 vendors within the Simplified Acquisition Threshold tested, the School did not maintain documentation that appropriate procurement procedures were performed or provide documentation to support the School’s reasoning for a noncompetitive procurement. Recommendation: The School should review its procurement procedures to ensure that proper procurement procedures are performed documentation is maintained to support the procurement. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer

Corrective Action Plan

2024-002: Procurement Type of Finding: Noncompliance, Material Weakness Condition: The School did not always follow procurement standards as put forth in 2 CFR §200.318 through §200.326. Context: For two of 25 vendors within the Simplified Acquisition Threshold tested, the School did not maintain documentation that appropriate procurement procedures were performed or provide documentation to support the School's reasoning for a noncompetitive procurement. Repeat Finding: Similar to prior year finding 2023-003. Action planned in response to finding: Management will implement procedures to ensure that competitive purchasing procedures are performed for all transactions above the micro purchase threshold and documentation is maintained to support the procurement procedures performed. Planned completion date for corrective action plan: June 30, 2025 Name of the contact person responsible for corrective action: Dolores Silva, Chief Financial Officer

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1153124 2024-002
    Material Weakness Repeat
  • 1153126 2024-003
    Material Weakness Repeat
  • 1153127 2024-004
    Material Weakness Repeat
  • 1153128 2024-004
    Material Weakness Repeat
  • 1153129 2024-004
    Material Weakness Repeat
  • 1153130 2024-004
    Material Weakness Repeat
  • 1153131 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $3.95M
15.046 Administrative Cost Grants for Indian Schools $1.50M
15.047 Indian Education Facilities, Operations, and Maintenance $782,276
84.027 Special Education Grants to States $770,928
15.042 Indian School Equalization $743,457
15.044 Indian Schools Student Transportation $560,511
84.336 Teacher Quality Partnership Grants $377,974
10.555 National School Lunch Program $311,966
84.287 Twenty-First Century Community Learning Centers $220,371
84.424 Student Support and Academic Enrichment Program $134,393
84.060 Indian Education Grants to Local Educational Agencies $133,637
10.553 School Breakfast Program $121,201
84.010 Title I Grants to Local Educational Agencies $107,364
15.043 Indian Child and Family Education $51,678
84.196 Education for Homeless Children and Youth $32,186
15.149 Focus on Student Achievement $10,968
10.559 Summer Food Service Program for Children $10,080
15.151 Education Enhancements $1,796