Finding 3169 (2023-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2023-12-04

AI Summary

  • Core Issue: The School District lacks written policies for verifying vendor debarment and suspension as required by Federal guidelines.
  • Impacted Requirements: Compliance with Uniform Guidance policies and 2 CFR Part 180 regarding internal controls for SAMS.gov vendor verification.
  • Recommended Follow-Up: The Board of Trustees should update internal control policies to include necessary guidelines for Federal Grant Expenditures and ensure compliance with Federal Award requirements.

Finding Text

2023-003 Procurement SAMS.gov - Significant Deficiency ALN: 84.425 Criteria: Uniform Guidance policies, 2 CRF Part 180, states written policies and procedures related to internal controls be written and documented in regard to SAMS.gov vendor verification of debarment and suspension. Cause: The School District does not have internal control Federal written updated policies implementing Debarment and Suspension. Condition: While detail testing found no unallowed costs, without written policies addressing the verification of vendor suspensions or debarment, vendors could be debarred or suspended that are paid under Federal contracts. The School District could not provide documentation that vendors paid - were verified through SAMS.gov for debarment or suspension. Effect: The School District must use funds as required under the Federal Award guidelines under Uniform Guidance to prevent mismanagement of projects funded by Federal Awards. Questioned Costs: None. Recommendation: We recommend that the Board of Trustees and School Officials review Financial Internal Control Policies and ensure that Uniform Guidance policies are incorporated for Federal Grant Expenditures. These policies be reviewed with Federal Grant Award Guidelines.

Corrective Action Plan

The District has policies in place to ensure vendors paid under Federal contracts are not subject to debarment or suspension. Policy EFAB - DJ/DJA/DJB outlines these requirements. As of 11/10/2023, the District has taken corretive action regarding this finding by utilizing a custom field within our accounting software. Each vendor now contains a SAM.GOV VERIFICATION field where the Accounting Technician will note the date the vendor was verified along with their initials. This will be updated annually. If the vendor does not have a Unique Entity ID on SAM.gov, the Accounting Technician will utilize the Certification Regarding Debarment, Suspension, Ineligibility And Voluntary Exclusion contained in Policy EFAB-E(2).

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 3168 2023-002
    Significant Deficiency
  • 579610 2023-002
    Significant Deficiency
  • 579611 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States $366,786
10.555 National School Lunch Program $230,634
84.371 Striving Readers $145,947
84.010 Title I Grants to Local Educational Agencies $91,578
84.367 Improving Teacher Quality State Grants $74,340
84.424 Student Support and Academic Enrichment Program $59,543
84.425 Education Stabilization Fund $37,028
84.048 Career and Technical Education -- Basic Grants to States $22,776
84.173 Special Education_preschool Grants $3,646
93.368 21st Century Cures Act - Precision Medicine Initiative $2,228
84.196 Education for Homeless Children and Youth $1,214