Finding 1172460 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-02-05
Audit: 385625
Organization: Regional School Unit No. 18 (ME)

AI Summary

  • Core Issue: The School Unit failed to document checks confirming that contracted schools were not suspended or debarred.
  • Impacted Requirements: This violates the requirement for maintaining proper documentation under the Uniform Guidance for grant compliance.
  • Recommended Follow-Up: Management should implement a system to ensure annual documentation of suspension and debarment checks for all relevant vendors.

Finding Text

2025-001 – U.S. Department of Education, For the Period July 1, 2024, through June 30, 2025, Assistance Listing #84.027-84.173 – Internal Controls and Compliance over Special Education Cluster Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred, or otherwise excluded from participating in the transaction. In addition, under the requirements of fiscal management, grant recipients are required to design and implement internal controls to ensure compliance with grant requirements and their own policies and procedures. Condition: The School Unit contracted with schools to provide out-of-district tuition and did not document that the schools were not suspended or debarred as service providers. Cause: Although the School Unit verified the schools were not suspended or debarred through the site Sam.gov, no documentation was maintained to show such verification was performed. Effect: The School Unit is not in compliance with documentation requirements under the Uniform Guidance. Questioned Costs: None Recommendation: Management should ensure that documentation of suspension and debarment checks are maintained annually for all vendors for which suspension and debarment requirements apply. Documentation should be in accordance with the School Unit’s procurement policy and procedures.

Corrective Action Plan

Management’s response/corrective action plan: Management agrees with the finding. The School Unit acknowledges that while suspension and debarment verifications for out-of-district tuition providers were performed through SAM.gov, documentation evidencing those verifications was not formally retained. This occurred because the verification process was conducted as part of normal procurement due diligence; however, procedures did not explicitly require the retention of proof of those checks. RSU 18 will ensure that procedures will require documentation of suspension and debarment checks for all vendors and service providers subject to Uniform Guidance requirements. The school unit will utilize screenshots of vendors search on SAM.gov or signed vendor certifications/attestations as evidence for compliance. The records will be maintained with the Business office and reviewed prior to entering a new contract, renewal, or when required by federal program guidance. Management believes these corrective actions will strengthen internal controls, ensure compliance with Uniform Guidance documentation requirements, and prevent recurrence of this issue in future audit periods.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1172458 2025-001
    Material Weakness Repeat
  • 1172459 2025-002
    Material Weakness Repeat
  • 1172461 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Elementary and Secondary School Emergency Relief Fund (ESSER) 3 - COVID $1.20M
84.027 Special Education Grants to States $983,605
84.010 Title 1A - Basic Disadvantaged Program $550,649
10.555 NATIONAL SCHOOL LUNCH PROGRAM $549,458
84.367 Title IIA - Supporting Effective Instruction $240,802
10.553 National School Breakfast Program $151,993
10.555 National School Lunch Program - Donated Commodities $130,586
10.582 National School Lunch - Fresh Fruits and Vegetables $31,150
10.559 National School Lunch - Summer Food Service $19,477
84.358 Rural and Low Income $17,675
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $14,440
84.425 Educator workforce shortages - COVID $3,140
84.425 Learning Loss (Literacy grant)- COVID $1,299