Finding 1206095 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-04-08

AI Summary

  • Core Issue: The District failed to obtain necessary contracts and competitive bids for vendors in the Child Nutrition and Special Education programs.
  • Impacted Requirements: Noncompliance with Uniform Guidance and Massachusetts General Law regarding procurement procedures increases risks of unallowable costs.
  • Recommended Follow-Up: Strengthen procurement controls to ensure adherence to federal and state requirements for competitive bidding and contract documentation.

Finding Text

2025-001 Improve Procurement Process Federal Agency: U.S. Department of Education Cluster/Program: Child Nutrition Cluster AL Number(s): 10.553/10.555 Award Year: 2025 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 – Material Weakness Criteria or Specific Requirement Uniform Guidance (2 CFR § 200.318–200.320) requires recipients of federal funds to follow their own documented procurement procedures, which must conform to applicable federal and state laws and promote full and open competition. For large purchases, Uniform Guidance and Massachusetts General Law (MGL) require obtaining competitive proposal or sealed bids. Additionally, proper contract documentation must be maintained for vendor relationships. Condition and Context The primary vendor tested for procurement under the Child Nutrition Cluster program did not have a signed contract or proof of the competitive procurement process for fiscal year 2025. Further, the Special Education Cluster did not have quotes for vendors tested or recent sole source letters on file. Effect or Potential Effect Noncompliance with policies and procedures regarding required procurement practices with vendors increases the risk of noncompliance with federal procurement requirements, lack of competition, and unallowable costs. Questioned Costs: None. Cause The District did not implement adequate controls to ensure compliance with procurement policies for obtaining sufficient quotes or competitive bids and did not formalize vendor relationships with contracts as required. Recommendation The District should strengthen its procurement controls by ensuring that the Uniform Guidance and MGL procurement practices are followed. Views of Responsible Official and Planned Corrective Action Management’s views and Corrective Action Plan are included at the end of this report.

Corrective Action Plan

Audit Finding Reference: 2025-001 Planned Corrective Action: The Student Services and Food Service departments in Southwick-Tolland-Granville Regional School District will immediately ensure complete implementation of our internal control protocols regarding procurement. For any purchase that requires competitive procurement, we will conduct market research, obtain multiple quotes, or use the IFB/RFP process, if necessary. We will only engage in sole source procurement when we have determined that there is only one single provider of the good or service, and we will document that determination accordingly. We will enter into contracts with vendors when purchasing goods or services from them. We will use purchase orders to ensure that funds are encumbered and not over expended. Lastly, we will keep all procurement documentation on file, including quotes, bids, and sole source letters. Staff who engage in our purchasing process, including our Director of Student Services, our Director of School Nutrition, our Supervisor of Buildings and Grounds, and our Director of Technology will be retrained in our procurement protocols and will be expected to implement them immediately going forward. The Director of Finance and Operations will review all purchase requisitions to ensure that the appropriate steps have been taken. Planned Implementation Date of Corrective Action: April 17, 2026 Person Responsible for Corrective Action: Nicholas Bernier Director of Finance and Operations Southwick-Tolland-Granville Regional School District

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1206088 2025-001
    Material Weakness Repeat
  • 1206089 2025-001
    Material Weakness Repeat
  • 1206090 2025-001
    Material Weakness Repeat
  • 1206091 2025-001
    Material Weakness Repeat
  • 1206092 2025-001
    Material Weakness Repeat
  • 1206093 2025-001
    Material Weakness Repeat
  • 1206094 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 NATIONAL SCHOOL LUNCH PROGRAM $259,705
10.553 SCHOOL BREAKFAST PROGRAM $108,343
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $16,535
84.027 SPECIAL EDUCATION GRANTS TO STATES $13,786
84.425 COVID-19 EDUCATION STABILIZATION FUND $7,912
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $7,139
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $3,301
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $2,770
10.182 COVID-19 PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $724