Finding Text
FINDING REFERENCE NUMBER 2025-008 FEDERAL PROGRAMS (ALN – 84.027) SPECIAL EDUCATION – GRANTS TO STATES (IDEA, PART B) – SPECIAL EDUCATION CLUSTER (IDEA) (ALN – 84.173) SPECIAL EDUCATION – PRESCHOOL GRANTS (IDEA PRESCHOOL) – SPECIAL EDUCATION CLUSTER (IDEA) U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS H027A230003 (07/01/2023 – 09/30/2024); H027A240003 (07/01/2024 – 09/30/2025); H173A230003 (07/01/2023 – 09/30/2024); H173A240003 (07/01/2024 – 09/30/2025); COMPLIANCE REQUIREMENT PROCUREMENT AND SUSPENSION AND DEBARMENT TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE CRITERIA 2 CFR Section 200.317, establishes that when conducting procurement transactions under a Federal award, a State or Indian Tribe must follow the same policies and procedures it uses for procurements with non-Federal funds. 2 CFR §200.318(a)(i) establishes that the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. STATEMENT OF CONDITION As part of our audit procedures over procurement process, we requested a list of all procurement procedures performed related to professional services and direct services to participants. No information was provided related to procurement procedures. In relation to quotation process, we selected a sample of forty (40) transactions for which a quotation process should have been performed. We found the following deficiencies: 1. In one quotation process, we were not provided with the document listing the bidders, evidence of the bidder selection, and the reasons for that selection. 2. In another quotation process, the requisition specifying the goods for which quotations were requested did not correspond to the fiscal year and made no reference to the quotations submitted. In addition, we requested a detailed list of all contracts formalized during the year and financed with IDEA funds. When selecting a sample of twenty-five (25) contracts, we were informed that several were financed with State funds. We requested the list of IDEA program contracts again, but it was not provided. This constitutes a scope limitation. QUESTIONED COSTS None. PERSPECTIVE INFORMATION After we requested all the supporting information related to procurement processes and contracts, the PRDE was not able to provide the basic documentation for the procurement performed and a list of contracts with IDEA funding during a reasonable period of time. This is a systemic deficiency that should properly be corrected, and the information should be available for audit process. The samples were statistically valid samples. STATEMENT OF CAUSE The IDEA program performs a procurement process related to specific services for which no evidence of the procurement performed was provided. The PRDE does not maintain a detail of contracts financed with IDEA funding. In addition, quotations for some purchases are performed through the Purchase Department of the PRDE, and no proper controls over the documentation are maintained POSSIBLE ASSERTED EFFECT Due to the lack of filing documentation related to the procurements performed and formalized contracts, we were unable to ascertain compliance with the procurement and suspension and debarment process. In relation to the quotation process, PRDE is not maintaining proper documentation to demonstrate compliance with procurement. IDENTIFICATION OF REPEAT FINDING This is a repeat finding (Finding Reference Number 2024-009). RECOMMENDATIONS We recommend that the PRDE review its internal control procedures for filings to ensure that all procurement documentation is readily available to any auditor or entity tasked with assessing the procurement process.