Finding 1241276 (2023-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2026-10-28
Audit: 415407
Organization: Little Wound School Board, Inc. (SD)
Auditor: BLUEARROW CPA

AI Summary

  • Core Issue: The School lacks sufficient documentation for procurement transactions, particularly regarding suspension and debarment verification and sole-source justifications.
  • Impacted Requirements: Noncompliance with 2 CFR § 200.318(i) and 2 CFR § 200.214 increases risks related to Federal procurement standards.
  • Recommended Follow-Up: Strengthen vendor selection procedures, ensure proper documentation for noncompetitive procurements, and verify suspension/debarment status before contracts.

Finding Text

Identification of Major Programs Affected: This finding relates to all major programs Criteria: Title 2, U.S. Code of Federal Regulations (CFR), Part 200 establishes procurement requirements applicable to purchases made with Federal awards. 2 CFR § 200.318(i) requires the School to maintain records sufficient to detail the history of procurement transactions. Such records should include, as applicable, the rationale for the method of procurement, selection of the contractor, reasons for contractor selection or rejection, and the basis for the contract price. Additionally, 2 CFR § 200.214 requires compliance with the suspension and debarment requirements contained in 2 CFR Part 180. Under 2 CFR § 180.300, prior to entering into an applicable covered transaction, the School is required to verify that the prospective contractor or vendor is not excluded or disqualified from participation in Federal programs. Verification may be accomplished by reviewing the System for Award Management (SAM.gov), obtaining an appropriate certification from the vendor, or including an applicable clause or condition in the transaction. According to 2 CFR section 200.319, all procurement transactions for acquiring property or services required under a Federal award must be conducted with full and open competition. This ensures fairness and transparency in the procurement process, consistent with the standards outlined in this section and § 200.320. Condition: During our testing of procurement transactions charged to the Federal program, we noted that the School did not maintain sufficient documentation to demonstrate that suspension and debarment verification was performed at the time applicable contracts or covered transactions were entered into. In addition, for certain noncompetitive procurements, the School was unable to provide documentation supporting the sole-source justification or demonstrating that an allowable condition for noncompetitive procurement was met. Cause: The School did not have adequate procedures in place to ensure that suspension and debarment verification and documentation supporting sole-source procurements were completed and retained prior to entering into federally funded contracts. Effect: Noncompliance with procurement requirements under Uniform Guidance and School procurement policy. The lack of adequate procurement documentation increases the risk that purchases made with Federal funds may not comply with Federal procurement requirements or may not be obtained through appropriate competition. Additionally, failure to document suspension and debarment verification increases the risk that the School could enter into a covered transaction with a vendor that is suspended, debarred, or otherwise excluded from participation in Federal programs. Auditor's Recommendations: The School should strengthen its vendor selection procedures and ensure adherence to procurement policies to minimize risks and enhance efficiency. Noncompetitive or sole-source procurements should include written documentation supporting the applicable allowable circumstance under 2 CFR § 200.320. The rationale for the procurement method, vendor selection, and basis for the contract price should be retained in the procurement file. Suspension and debarment status is verified prior to entering into applicable covered transactions using one of the methods permitted under 2 CFR Part 180, and evidence of such verification is retained.

Corrective Action Plan

Response: Suspension and Debarment checks were conducted for purchases over $100,000 for construction contracts for FI&R projects, but the documentation was not printed out and put in a file. We are working on implementing a system to have this information included in the vendor file. Because Little Wound School is in a rural area sometimes it is difficult to get 3 quotes from vendors in the area or that will even give us a quote on large items. So there are times that we are only able to get one bid or quote so we take that to our School Board for approval. So what we are going to do if this happens is we will add it to the School Board motion that it is a sole source if we are not able to secure the proper number of quotes. Estimated completion date: November 1, 2026 Responsible party: Business Manager, Assistant Business Manager and Procurement.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1241271 2023-002
    Material Weakness Repeat
  • 1241272 2023-002
    Material Weakness Repeat
  • 1241273 2023-002
    Material Weakness Repeat
  • 1241274 2023-002
    Material Weakness Repeat
  • 1241275 2023-002
    Material Weakness Repeat
  • 1241277 2023-003
    Material Weakness Repeat
  • 1241278 2023-003
    Material Weakness Repeat
  • 1241279 2023-003
    Material Weakness Repeat
  • 1241280 2023-003
    Material Weakness Repeat
  • 1241281 2023-003
    Material Weakness Repeat
  • 1241282 2023-003
    Material Weakness Repeat
  • 1241283 2023-004
    Material Weakness Repeat
  • 1241284 2023-004
    Material Weakness Repeat
  • 1241285 2023-004
    Material Weakness Repeat
  • 1241286 2023-004
    Material Weakness Repeat
  • 1241287 2023-004
    Material Weakness Repeat
  • 1241288 2023-004
    Material Weakness Repeat
  • 1241289 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.042 INDIAN SCHOOL EQUALIZATION $7.45M
84.425 EDUCATION STABILIZATION FUND $4.21M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $3.60M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $2.31M
15.046 ADMINISTRATIVE COST GRANTS FOR INDIAN SCHOOLS $1.99M
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.65M
15.044 INDIAN SCHOOLS STUDENT TRANSPORTATION $1.33M
15.047 INDIAN EDUCATION FACILITIES, OPERATIONS, AND MAINTENANCE $1.32M
93.665 EMERGENCY GRANTS TO ADDRESS MENTAL AND SUBSTANCE USE DISORDERS DURING COVID-19 $773,316
15.062 REPLACEMENT AND REPAIR OF INDIAN SCHOOLS $647,201
15.043 INDIAN CHILD AND FAMILY EDUCATION $372,349
10.555 NATIONAL SCHOOL LUNCH PROGRAM $272,349
84.299 INDIAN EDUCATION -- SPECIAL PROGRAMS FOR INDIAN CHILDREN $241,446
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $203,600
84.299A Special Projects Demonstration Grants $150,166
15.149 FOCUS ON STUDENT ACHIEVEMENT $145,916
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $139,686
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $129,900
84.101 CAREER AND TECHNICAL EDUCATION - GRANTS TO NATIVE AMERICANS AND ALASKA NATIVES $126,147
10.553 SCHOOL BREAKFAST PROGRAM $93,584
84.415 INDIAN EDUCATION NATIONAL ACTIVITIES (STATE TRIBAL EDUCATION PARTNERSHIP (STEP) AND NATIVE AMERICAN LANGUAGE (NAL) $65,908
84.377 SCHOOL IMPROVEMENT GRANTS $29,895
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $24,931
10.575 FARM TO SCHOOL GRANT PROGRAM $22,341
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $19,166
10.558 CHILD AND ADULT CARE FOOD PROGRAM $17,086
84.358 RURAL EDUCATION $10,900
45.164 PROMOTION OF THE HUMANITIES PUBLIC PROGRAMS $5,122