Finding 12602 (2022-001)

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Requirement
I
Questioned Costs
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Year
2022
Accepted
2023-03-26
Audit: 17482
Organization: Trinity Area School District (PA)

AI Summary

  • Core Issue: The District did not follow proper procurement procedures for federal ESSER fund purchases over $10,000, failing to obtain three quotes.
  • Impacted Requirements: Compliance with federal procurement regulations was not met, as reliance on cooperative purchasing programs does not fulfill the necessary quote/bid requirements.
  • Recommended Follow-Up: Ensure all federal purchases have adequate documentation, obtain at least three quotes, and clearly justify any sole source exceptions.

Finding Text

Finding Criteria ? A component of compliance relating to federal awards is maintaining records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition Found ? The District used federal ESSER funds to make a purchase greater than $10,000 to $21,900 without obtaining at least three quotes. Cause of the Finding ? The District was under the false notion that purchases made through the Commonwealth of Pennsylvania?s cooperative purchasing program COSTARS satisfied compliance requirement of quote/bid requirements for federal purchases. Effect of the Finding ? The District was not in compliance with procurement requirements for federal funds. Questioned Costs ? No questioned cost Recommendations - Documentation is key for all federal purchases. A purchase price from cooperative purchasing programs can be considered one competitive price proposal and cannot replace a procurement process. Advertise when appropriate, obtain adequate quote/bid information from three vendors, and thoroughly document the ?reason? and ?cost analysis? of sole source noncompetitive procurement exceptions. Management's Response - The District will follow the policy for quotation/bid requirements for federal purchases and not use cooperative purchasing programs as the only source of quotations/bids for federal purchases. The District will also improve documentation relating to purchases that meet sole source criteria.

Corrective Action Plan

We were under the false notion that purchases made through the Commonwealth of Pennsylvania?s cooperative purchasing program (COSTAR) satisfied compliance of quote/bid requirements of federal purchases. We will follow our policy for federal purchases subject to quotation/bid requirements moving forward. When federal money is used, we will not use cooperative purchasing programs as the only source of quotation/bid for federal purchases. We also implemented processes to improve documentation relating to purchases that meet sole source criteria. Anticipated Completion Date: The District will implement the above procedure immediately

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $882,955
10.553 School Breakfast Program $518,531
84.010 Title I Grants to Local Educational Agencies $513,701
84.027 Special Education_grants to States $139,280
84.367 Improving Teacher Quality State Grants $90,253
12.357 Rotc Language and Culture Training Grants $67,567
93.778 Medical Assistance Program $45,410
10.559 Summer Food Service Program for Children $41,526
84.424 Student Support and Academic Enrichment Program $39,038
10.555 National School Lunch Program $38,261
32.009 Emergency Connectivity Fund Program $24,107
10.558 Child and Adult Care Food Program $6,383
10.649 Pandemic Ebt Administrative Costs $3,063
84.173 Special Education_preschool Grants $2,988