Finding Text
Finding 2025-002 - Internal Controls over Procurement, Suspension and Debarment U.S. Department of Education Pass-through S.C. Department of Education Special Education Cluster ALN 84.027 & 84.173 Grant / FAIN: 23 IDEA / H027A230081 Grant Period: 07/01/22 - 09/30/24 24 IDEA / H027A230081 Grant Period: 07/01/23 - 09/30/25 25 IDEA / H027A230081 Grant Period: 07/01/24 - 09/30/26 24 IDEA Preschool / H173A230085 Grant Period: 07/01/23 - 09/30/25 25 IDEA Preschool / H173A240085 Grant Period: 07/01/24 - 09/30/26 Questioned Costs: None Criteria: Prior to expending federal funds with any vendor, the District is required to check to ensure the vendor has not been either (1) suspended or (2) debarred from doing business with governmental entities. This should be done on the System for Award Management (SAM.gov). Condition: The District did not check SAM.gov to ensure the vendors utilized during the current fiscal year were suspended or debarred from doing business with governmental entities. Cause: The previous CFO had been the one in prior years to check fo rsuspended and debarredvendors. Due to his retirement, the new CFO was not aware of this requirement. Effect or Potential Effect: The District could spend money with vendors that are not allowed to do government work causing the District to fund those expenditures out of the general fund or non-federal money when it was intended to be federally funded. Context: Out of a sample of 25 vendors tested, no vendors were found to be suspended or debarred. However, upon inquiry with District staff, it was determined that the actual verification was not being performed. Because District staff was unaware of the requirement, we determine this to be a systemic issue. Repeat Finding: This is not a repeat finding. Recommendation: The District should implement strict internal controls that every vendor is verified at the start of the year to SAM.gov when the purchase orders are being prepared by the various departments. This will ensure that no purchase orders, or subsequent purchases, are made to vendors that are suspended or debarred from either federal or local funds. Views of Responsible Officials: The finance department will verify with SAM.gov that any new vendors are neither suspended or debarred from doing business with the school district.