Finding Text
Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00813 N/A Administrative Cost Grants for Indian Schools 15.046 A23AV00813 N/A Special Education Cluster (IDEA) 84.027 A24AV00760 N/A Federal Agency(ies): U.S. Department of Interior Pass‐Through Agency(ies): Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non‐federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition The School’s internal controls over procurement of goods and services were not adequate. Cause The School has procures in place to perform procurement, suspension, and debarment in accordance with federal regulations and guidelines, however, they were not followed. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context - The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to two vendors with the Special Education Cluster (IDEA) and one vendor with the Administrative Cost Grants for Indian Schools. - For three non‐cooperative‐purchase vendors paid in excess of the small purchase threshold ($10,000), the School did not prepare and maintain documentation for at least 3 written quotes from qualified sources. The deficiency applied to two vendors with the Administrative Cost Grant, and one vendor with the Special Education Cluster (IDEA). -For all eight vendors procured via sole source reviewed, the School did not prepare and maintain documentation in accordance with School policy that there was only one sole source and that the determination was reasonable. Additionally, the School did not present the procurement to the Board for approval as a sole source for all eight vendors. The deficiency applied to five vendors procured through funding from the Administrative Cost Grant for Indian Schools, two vendors procured through funding from the Indian School Equalization Program, and one vendor which was procured through various sources of federal funding. -For the first of three vendors reviewed with whom the School had purchases exceeding $50,000 during the fiscal year, the School did not perform a sealed procurement. For the second of three vendors reviewed with whom the School had purchases exceeding $50,000 during the fiscal year, the School did not retain evidence that a sealed procurement was performed. Finally, for the third of three vendors reviewed with whom the School had purchases exceeding $50,000, the School did not maintain evidence that bids were solicited from an adequate known suppliers, were opened at the prescribed time and place, and that the award was made to the lowest responsive/responsible bidder. All three deficiencies applied to the Special Education Cluster (IDEA). The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.