Finding 1202969 (2025-003)

2025-003 Improve Controls and Documentation Over Procurement Federal Agency: U.S. Department of Education Cluster/Program: Special Education Cluster AL Number(s): 84.027/84.173 Award Year: 2025 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Uniform Guidance (2 CFR § 200.320) permits noncompetitive (sole source) procurements only when specific conditions are met, such as when the item is available from a single source, and requires documentation justifying the sole source determination. All procurement transactions must be conducted in a manner providing full and open competition, to the maximum extent practicable. Condition and Context Of the two vendors tested for procurement transactions under the Special Education Cluster, support could not be provided for one vendor to justify that they were the only vendor capable of providing the product and that the purchase therefore met the requirements for a sole source procurement. Effect or Potential Effect Lack of documentation to support justification for sole source procurement increases the risk of noncompliance with Uniform Guidance, limits transparency, and could allow for inappropriate procurement practices. Questioned Costs Not determinable. Cause The School Department did not have controls to ensure that sole source procurement transactions are properly documented in accordance with federal requirements. Recommendation The School Department should enhance its procurement controls to ensure all sole source purchases are fully documented with justification in accordance with Uniform Guidance, and maintain supporting records for all federal procurement transactions. Views of Responsible Official and Planned Corrective Action Management’s views and Corrective Action Plan are included at the end of this report after the summary Schedule of Prior Year Findings.