Finding Text
Finding No. 2022-006?HEERF Procurement (Repeating Finding?2021-001) Federal Agency: U.S. Department of Education Program: COVID-19 Education Stabilization Fund: ALN: 84.425 Criteria: Procurement standards under the Uniform Guidance 2 CFR 200.317-200.327 require that competitive bids be received for purchases above the micro-purchase level or justification for sole-source providers be documented prior to the purchase. Condition: During fiscal year 2022, certain costs were incurred above the micro-purchase level where there was no evidence of competitive bids received or documentation Questioned Costs: None. Prevalence: There was no direct outreach and no costs were charged to the program. The sample was not intended to be, and was not, a statistically valid sample. Effect: Not complying with requirements outlined within applicable grant agreements could result in the DOE withholding payments to the Conservatory. Cause: This issue in the result of a lack of proper understanding of applicable requirements. Due to the timing of identifying the prior year finding, management was in the process of implementing the policy and procedures around federal compliance as of June 30, 2022. Recommendation: We recommend that the Conservatory follow the guidelines in its procurement policy or document any justification for departure from the policy. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and corrective actions will be made.