Finding Text
2024-003 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: District of Columbia Office of the State Superintendent of Education Award Period: May 25, 2022 - September 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: According to the Uniform Guidance (2 CFR Part 200), non-federal entities are required to establish and maintain effective internal controls over the procurement process. This includes having a documented procurement policy that ensures compliance with federal regulations, promotes fair competition, and prevents conflicts of interest. Condition: During our review, we noted that the organization does not have a documented procurement policy in place. This absence of a formal policy means that procurement activities are not guided by standardized procedures or controls. Questioned costs: None Context: The organization receives federal funding and is therefore subject to the requirements of the Uniform Guidance. A procurement policy is essential to ensure that all procurement activities are conducted in a manner that is consistent with federal regulations and best practices. Cause: The lack of a procurement policy appears to be due to oversight and a lack of awareness of the requirements under the Uniform Guidance. There may also be resource constraints that have prevented the development and implementation of such a policy. SPRINGBOARD COLLABORATIVE SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED DECEMBER 31, 2024 (30) Effect: The absence of a procurement policy increases the risk of noncompliance with federal regulations, potential financial mismanagement, and conflicts of interest. It also undermines the integrity and transparency of the procurement process, which could lead to unfavorable audit findings and potential loss of funding. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend that the organization develop and implement a comprehensive procurement policy that aligns with the Uniform Guidance. This policy should include clear procedures for procurement planning, solicitation, evaluation, and contract management; provisions to ensure fair competition and prevent conflicts of interest; training for staff on the procurement policy and federal requirements; and regular reviews and updates to the policy to ensure ongoing compliance. Views of responsible officials: Please refer to Springboard Collaborative’s Corrective Action Plan.