Finding 1240005 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-10-06

AI Summary

  • Core Issue: The District failed to verify vendor suspension and debarment status before awarding contracts.
  • Impacted Requirements: Compliance with 2 CFR 200.213 and 2 CFR 180.300 regarding vendor eligibility for federal assistance.
  • Recommended Follow-up: Ensure adherence to procurement policies and maintain documentation to confirm vendor eligibility.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: IDEA Assistance Listing Number: 84.027/84.173 Pass-through Agency: Chester County Intermediate Unity Pass-through Entity Number: 062-2500024 Federal Award Identification Number and Year: H027A200093 - 2025 Award Period: 7/1/2024 to 6/30/2025 Compliance Requirement: Suspension and Debarment TREDYFFRIN-EASTTOWN SCHOOL DISTRICT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED JUNE 30, 2025 (137) Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Internal Control: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work to individuals and firms or economic considerations. Condition: The District could not provide supporting documentation that suspension and debarment status was determined prior to award. Questioned Costs: None Context: The District did not adhere to established internal controls over suspension and debarment transactions Cause: The District did not retain documentation that the vendor was not suspended or debarred at time of contract. Effect: There is a risk that vendors utilized are suspended by the SEC. Repeat Finding: No Recommendation: The District should ensure that employees are following the requirements they have outlined in their procurement policy. Views of Responsible Officials: Management acknowledges and accepts the finding and has implemented controls to ensure the finding will not reoccur.

Corrective Action Plan

Special Education Cluster – Assistance Listing No. 84.027, 84.173 Recommendation: The District should ensure that employees are following the requirements they have outlined in their procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented corrective actions to ensure compliance with federal suspension and debarment requirements as stated in existing Policy/Regulation 3233. Procedures have been established requiring verification of vendor eligibility through SAM.gov or documented certification prior to the award of any federally funded contract by Purchasing Department, as well as ongoing monitoring to ensure continued eligibility throughout the contract period. Supporting documentation evidencing this verification will be retained for all vendors associated with federal expenditures. The District is implementing review controls to ensure compliance prior to contract execution and payment processing. Additionally, relevant personnel will receive training on federal compliance requirements, and Business Manager or designee will perform periodic monitoring to confirm that controls are operating effectively and that documentation is consistently maintained, thereby reducing the risk of noncompliance in future periods. Name(s) of the contact person(s) responsible for corrective action: Arthur J. McDonnell Planned completion date for corrective action plan: Immediately

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1240003 2025-002
    Material Weakness Repeat
  • 1240004 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.08M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $226,364
10.555 NATIONAL SCHOOL LUNCH PROGRAM $148,009
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $89,572
10.553 SCHOOL BREAKFAST PROGRAM $88,200
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $59,375
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $18,419
93.778 GRANTS TO STATES FOR MEDICAID $14,996
84.425 EDUCATION STABILIZATION FUND $14,204
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $3,335