Finding 1175532 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-02-26

AI Summary

  • Core Issue: The District failed to document the rationale for a $40,000 purchase from Western PA Psych Care, violating procurement guidelines.
  • Impacted Requirements: Noncompliance with Section 2 CFR 200.318(i) and Section 2 CFR 200.320(c) of the Uniform Guidance, as well as District Procurement Policy #626.
  • Recommended Follow-Up: Ensure all future noncompetitive procurements follow the District’s Procurement Policy and Uniform Guidance requirements.

Finding Text

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Western PA Psych Care’ totaling $40,000. This is a repeat finding 2024-001 from the previous fiscal year. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance, and District Procurement Policy #626, regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: $40,000 CAUSE: The District has had a long-standing relationship with Western PA Psych Care and feels that this vendor best fits the needs of the District. However, the additional procedures addressed in its Procurement Policy for Federal Programs (#626) which addresses the issue of noncompetitive procurement as outlined in Section 2 CFR 200.320(c’), were inadvertently not performed. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

Corrective Action Plan

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Western PA Psych Care’ totaling $40,000. This is a repeat finding from the previous fiscal year 2024-001 CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, the District adheres to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance.MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The District’s timeframe for implementation is effective immediately. The District has a formal procurement policy for federal programs (#626) in place. The District hired a Business Manager effective with the 2024-2025 fiscal year who, in conjunction with the District’s Federal Program Coordinator, will be responsible for following the District’s existing procurement policy for federal programs, in particular related to this finding, the implementation of noncompetitive procurement procedures to ensure that they are followed appropriately. The implementation of this procedure took place after the questioned cost noted this fiscal year and will be effective for all future District procurements.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1175530 2025-001
    Material Weakness Repeat
  • 1175531 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $309,876
10.553 SCHOOL BREAKFAST PROGRAM $193,795
10.555 NATIONAL SCHOOL LUNCH PROGRAM $90,998
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $56,005
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $50,839
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $23,671
93.778 MEDICAL ASSISTANCE PROGRAM $6,253
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $5,166
84.425 EDUCATION STABILIZATION FUND $3,753
84.027 SPECIAL EDUCATION GRANTS TO STATES $3,110