Finding 1164977 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2025-12-16

AI Summary

  • Core Issue: Procurement procedures were not followed, leading to noncompliance with federal regulations regarding competition and vendor checks.
  • Impacted Requirements: Failure to solicit bids and verify contractor eligibility increases risks of noncompliance and potential ineligible costs.
  • Recommended Follow-Up: Strengthen procurement processes by ensuring bids are solicited, conducting vendor checks via SAM.gov, and providing staff training on compliance.

Finding Text

2025-003: Procurement Procedures (Significant Deficiency and Noncompliance) Federal Program: IDEA Special Education Federal ALN: 84.027/84.173 Criteria: Under 2 CFR §200.318-§200.320, non-federal entities must conduct all procurement transactions in a manner providing full and open competition and must follow documented procurement procedures consistent with federal standards. Additionally, 2 CFR §200.214 (previously §200.213) requires non-federal entities to verify that contractors are not suspended or debarred from doing business with the federal government. This verification may be accomplished by checking the System for Award Management (SAM.gov) or obtaining a certification from the vendor. Condition and Context: During our testing of procurement transactions, we identified two (2) contracts in which bids were not solicited as required by the District's procurement policy and Uniform Guidance. In addition, suspension and debarment checks were not performed or documented for these vendors prior to contract award. Cause: The exceptions occurred because procurement procedures were not consistently followed, and management did not perform or document required suspension/debarment verifications prior to contract execution. This may have been due to oversight or lack of staff training regarding Uniform Guidance procurement requirements. Effect or Potential Effect: Failure to solicit bids and perform suspension/debarment checks increases the risk of noncompliance with federal regulations, potential ineligible costs charged to federal programs, and diminished assurance that contracts are awarded fairly and to responsible parties. Questioned Costs: None. Identification as a Repeat Finding: No. Recommendation: We recommend that management strengthen procurement procedures to ensure compliance with Uniform Guidance requirements. Specifically: - Solicit bids or proposals in accordance with applicable competitive procurement thresholds; - Perform and document suspension and debarment checks (e.g., through SAM.gov) prior to awarding contracts; and - Provide staff training on federal procurement standards and maintain documentation supporting compliance for each federally funded procurement. Responsible Official's Response: Please see the last page of this report for the response to this finding.

Corrective Action Plan

Corrective Action Plan for Audit Finding 2025-003: Procurement Procedures (Significant Deficiency and Noncompliance - IDEA Special Education Federal Program) Finding Summary: Auditors identified two instances in which procurement transactions did not comply with the District's procurement policy or federal Uniform Guidance requirements. Specifically, bids were not solicited as required, and suspension and debarment checks were not performed or documented for the vendors prior to contract award. Root Cause: The exceptions occured due to a gap in the District's internal control structure. These procedures were not being consistently performed, and prior management was unaware the requirements under federal Uniform Guidance were not being followed. Corrective Action: The District will establish and implement policies and procedures to ensure all federally funded procurements comply with Uniform Guidance requirements. This includes: 1. Soliciting bids or proposals in accordance with applicable competitive procurement thresholds. 2. Performing and documenting suspension and debarment verifications for all vendors, including tracking results appropriately. 3. Providing training to staff responsible for federal procurement to ensure ongoing compliance and understanding of federal requirements. These actions are intended to ensure that contracts are awarded fairly, to responsible parties, and in full compliance with federal regulations. Documentation of all procurement steps will be maintained to demonstrate compliance during future audits. Responsible Parties: Fiona Barry, Assistant CFO, and Matthew Gonzales, CFO, are responsible for overseeing implementation, ensuring proper documentation, and providing staff training. Timeline: The corrective actions are scheduled for implementation by March 2026 and will continue as part of the District's ongoing procurement compliance process.

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
10.553 SCHOOL BREAKFAST PROGRAM $445,000
93.600 HEAD START $432,411
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $167,991
10.558 CHILD AND ADULT CARE FOOD PROGRAM $149,740
10.555 NATIONAL SCHOOL LUNCH PROGRAM $107,278
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $77,756
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $62,939
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $62,058
66.039 DIESEL EMISSION REDUCTION ACT (DERA) NATIONAL GRANTS $61,000
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $43,000
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $32,716
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $30,513
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $25,464
84.196 EDUCATION FOR HOMELESS CHILDREN AND YOUTH $25,161
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $24,742
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $16,474
84.425 EDUCATION STABILIZATION FUND $12,962
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $7,196
84.027 SPECIAL EDUCATION GRANTS TO STATES $4,060
84.051 CAREER AND TECHNICAL EDUCATION -- NATIONAL PROGRAMS $2,103
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $1,616
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $895