Finding 3047 (2023-002)

Finding 2023-002 - Procurement, Suspension and Debarment U.S. Department of Justice Direct STOP School Violence ALN No: 16.839 Grant ID: 15PBJA-21-GG-04641-STOP Grant Period: June 30, 2023 Condition: Prior to expending federal funds, the District should ensure that it has followed proper procurement procedures and policies as defined by the District's procurement code, to include the creation of purchase orders to document the steps followed to properly procure the goods or services. Reason Improvement Needed: Management is responsible for establishing and maintaining effective internal control over the applicable compliance requirements for each federal program. Without controls ensuring that all purchases are paid from a purchase order, it is highly possible the District will expend funds that are not properly procured and will be required to return those funds to the federal agency. Cause of Condition: Contained in a sample of 25 selections, the District failed to properly document its procurement of 2 purchases with purchase orders and did not document the ratification of the purchases. Effect of Condition: The District could be liable for the expenditures from their local funds if the District cannot demonstrate that the funds expended in violation of the procurement code were, in fact, properly procured but not documented as such. Perspective Information: We do not find this to be a systemic issue. Based on our subsequent review of all expenditures from the major program, these two selections were the only two the District did not document with purchase orders. In addition, the District procured the goods/services appropriately, however could not substantiate them with purchase order documentation that was prepared prior to expending. Identification of Repeat Findings: This is a not a repeat finding. Recommendation: it is our recommendation that the District strictly enforce the policy that no purchases are made without a purchase order from federal funds and that the District continue to closely monitor all federal funds to ensure that only select purchases are made with out purchase orders per District policy. Benefits of Recommended Action: By implementing these recommendations, the District will ensure it is in compliance with the compliance requirements outlined in 2 CFR 200 for Procurement and will know that they are not spending money that has not been properly procured and that will not have to be returned after reimbursement. Client Response: The District has started a review process to ensure all expenditures are properly documented, especially those from federally funded grants, with purchase orders and will ensure that all additional documentation to support the decisions made within the purchase order are included in the file for support.