2 CFR ? 400.1 gives regulatory effect to the Department of Agriculture and 2 CFR 3474.1 gives regulatory effect for the Department of Education for 2 CFR ? 200.317 through 200.327 which describe specific procedures non-Federal entities must follow when making procurement transactions using Federal funds. 2 CFR ? 200.318(a) indicates a non-Federal entity must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and standards. 2 CFR ? 200.320 indicates the non-Federal entity must use the following methods of procurement: (a) Procurement by micro-purchases, which the aggregate dollar amount does not exceed the dollar threshold; (b) Procurement by small purchase procedures, which are procurements of relatively simple and informal nature, which do not exceed the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources; (c) Procurement by sealed bids, are purchases made with publicly solicited and a firm fixed price contract (lump-sum or unit price) is awarded to the responsible bidder whose bid, conforming with all material terms and conditions in the invitations to bid, is the lowest in price. In order to be feasible, a complete, adequate and realistic specification or purchase description is available, two or more responsible bidders are willing and able to compete effectively for the business, and the procurement lends itself to a firm fixed price contract and the selection of the successful bidder can be made principally on cost; (d) Procurement by competitive proposals, which is appropriate when purchases are large and competitive bidding is not appropriate, or (e) Procurement by non-competitive proposals, which are appropriate when an item can be obtained only from a sole source, the non-competitive proposals are specifically authorized in the Federal award, after solicitation through competitive means, competition is deemed in adequate, and/or the item must be purchased without delay due to an emergency or exigent circumstances. 2 CFR ? 200.318(i) indicates the non-Federal entity must maintain 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. Maple Heights City School District Board Policy EAG- Administration of Federal Grant Funds indicates all purchases of property and services using Federal funds must be conducted in accordance with all applicable Federal, State, and local laws and regulations, the Uniform Guidance, and the District's written policies and procedures. The District will perform a cost and price analysis for every procurement over the established simplified acquisition threshold. Purchasing records will be sufficiently maintained to detail the history of all procurements and must include at least the rationale for the method of procurement, selection of contract type, and contractor selection or rejection; the basis for the contract price; and verification that the contractor is not suspended or debarred. The District?s procurement policy does not indicate the number of quotations required when using the simplified acquisition threshold. Ohio Rev. Code ? 3313.46 indicates when a Board of Education determines to build, repair, enlarge, or demolish any school building with a cost in excess of $50,000, the Board is required to: 1. Prepare plans and specifications; 2. Advertised for bids once a week for not less than two consecutive weeks or as provided in Ohio Rev. Code ? 7.16, in a newspaper in general circulation in the district before the date specified for receiving bids. The board may also cause notice to be inserted in trade papers or other publications designated by it or to be distributed by electronic means, including posting the notice on the board?s internet web site. If the board posts the notice on its web site, it may eliminate the second notice otherwise required to be published in a newspaper of general circulation within the school district, provided that the first notice published in such newspaper meets all of the following requirements: (a) It is published at least two weeks before the opening of bids; (b) It includes a statement that the notice is posted on the board of education?s internet web site; (c) It includes the internet address of the board?s internet web site; and (d) It includes instructions describing how the notice may be accessed on the board?s internet web site; 3. Open the bids at the time and place specified by the Board in the advertisement for bids; 4. The award of the contract is to the lowest responsible bidder; 5. The contract is between the board and the bidders. The board is required to approve and retain estimates and make them available to the Auditor of State upon request; and, 6. If two or more bids are equal and are lower than any others, either may be accepted. However, the work is not to be divided among the bidders. The above requirements do not apply to: ? an urgent necessity; ? acquisition of educational materials used for teaching; ? any item which the Board, by a two-thirds vote, determines is available and can be obtained only through a single source; ? energy conservation measures, with the approval of two-thirds of the Board; ? acquisition of computer software or hardware for instructional purposes; or, ? School districts that participate in a joint purchasing contract are exempt from using competitive bidding. For one out of four vendors tested during our procurement testing of the Nutrition Cluster, the District did not maintain written justification documenting the history of the procurement. The vendor performed repairs on kitchen equipment totaling $37,382. The procurement was within the simplified acquisition threshold and quotes should have been obtained. The justification for using the vendor was provided verbally during the audit, with the District indicating the vendor was selected because of quick response time, past visits, and availability. Additionally, the District paid $303,004 for a roof replacement using Education Stabilization Fund- Elementary and Secondary School Emergency Relief (ESSER II) funds, which would be required to be competitively bid under the Ohio Rev. Code ? 3313.46 and 2 CFR 200.320. The District could not provide us with the following documentation: proof of the advertisement for bids of the project in a newspaper of general circulation in the District and/or advertisement of the project on the District?s website, the Board resolution approving the award of the contract, and the bid packages submitted from the losing bidders. Because of the lack of available documentation, the District was in non-compliance of the Federal procurement and Ohio competitive bidding requirements. Both of the issues noted above were due to a lack of internal controls regarding Federal procurement at the District. The District should adopt procedures to ensure the history of the procurement, including the rationale for the purchase method, selection of vendors, cost/price analysis (if applicable) and the reason for limiting competition, either because they are from a sole source provider or due to emergency or exigent circumstances are documented and maintain written documentation of such procedures. The District should also amend their procurement policy to indicate the number of quotations required when using the simplified acquisition threshold.