FAC Explorer

Finding 29042 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-12-14
Audit: 29709
Organization: Mountain Board of Cooperative Educational Services (CO)
Auditor: McPherson Goodrich Paolucci & Mihelich PC

AI Summary

  • Core Issue: Mountain Board of Cooperative Education's procurement policy lacks necessary language for compliance with federal regulations.
  • Impacted Requirements: The policy does not meet the standards outlined in 2 CFR 200.318 through 200.327 regarding procurement methods and thresholds.
  • Recommended Follow-Up: Update the procurement policy to include all compliance requirements to avoid potential non-compliance in future procurements.

Finding Text

Finding 2022-001 Prior Year Finding Number: N/A Type of Finding: Internal Control over Compliance Severity of Deficiency: Significant Deficiency Federal Agency: U.S. Department of Education CFDA#: 84.027, 84.173 ? Special Education Cluster Pass-through Entity: Colorado Department of Education Type of Compliance Requirement ? Criteria: Procurement, Suspension, and Debarment ? 2CFR ??200.318 through 200.327 Criteria or specific requirement: Internal control over procurement, suspension, and debarment for federal award programs as indicated within the Uniform Guidance as indicated from the following excerpt(s): ?200.318 ? General procurement standards (a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity?s documented procurement procedures must conform to the procurement standards identified in ??200.317 through 200.327. Condition: During our review of Mountain Board of Cooperative Education?s procurement policy, we noted it did not include all the required language to ensure full compliance with 2CFR ?? 200.318 through 200.327, particularly the requirements discussing the allowable procurement methods, dollar thresholds, and the requirements for each allowable method. Cause: Management was unaware that the procurement policy had to meet these compliance requirements. Effect: Mountain Board of Cooperative Education may procure property and services that are not in compliance with Uniform Guidance. Questioned Costs: There were no reportable questioned costs related to this finding. Recommendation: We recommend Mountain Board of Cooperative Education update their procurement policy to encompass all requirements set by 2 CFR ??200.318 through 200.327. View of responsible officials and planned corrective action: We agree with the above finding and have implemented an appropriate corrective action plan.

Corrective Action Plan

RE: Finding 2022-001: Internal Control over Compliance The following is the Corrective Action Plan (CAP) related to the noted finding. Corrective Action Plan Agency: Colorado Department of Education Audit Period: FY21-22 Audit Finding Number: 2022-001 Audit Finding Title: Internal Control over Compliance Specific Steps to be Taken: Mountain BOCES currently utilizes a mostly decentralized purchasing system. Improved documentation and trainings relating to procurement policies and procedures as well as increased internal controls were put into place during the second half of 2022 and will continue in 2023. Mountain BOCES has been re-writing these policies to include required language and alignment with 2CFR ?? 200.317 through 200.327, particularly the requirements discussing the allowable procurement methods, dollar thresholds, and the requirements for each allowable method. The procurement policy is undergoing a major rewrite in 2023 by the Executive Director and newly hired Business Manager to ensure sufficient internal controls and overall improved efficiencies. Anticipated Completion Date: Ongoing Name(s) and Title(s) of Contact Person Wendy Wyman Executive Director responsible for Correction Action: If you should have any questions or comments, please do not hesitate to contact me at wwyman@mtnboces.org.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 605484 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States $794,814
84.425 Education Stabilization Fund $62,231
84.173 Special Education_preschool Grants $31,294