Finding Text
2022-006 Suspension and Debarment Federal Program, Assistance Listing # and Year, Federal Agency, Pass-Through Entity: Special Education Cluster ? Grants to States, Assistance Listing #84.027, 2022, U.S. Department of Education, Louisiana Department of Education. Criteria or Specific Requirement: 2 CFR 200.303 requires the entity to establish and maintain effective internal controls over compliance with respect to federal awards and Section 1111(b)(2)(A) of the ESEA for compliance accountability. Proper internal controls require supporting documentation to be retained as evidence for effectiveness of the controls in place. Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction (i.e., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR 180.995 and agency adoption regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: CRI identified that the School Board did not have controls in place to verify whether vendors are suspended, debarred or otherwise excluded. Effect: Transactions could be entered into with vendors who are suspended, debarred, or otherwise excluded causing the program to not be in compliance with grant requirements, which could result in loss of federal funding or repayment of questioned costs. Questioned Cost: None. Cause: Lack of internal controls to verify whether vendors are suspended, debarred or otherwise excluded. Recommendation: We recommend the School Board implement policies and procedures to verify vendors are not suspended, debarred or otherwise excluded. Views of responsible officials and corrective action plan: The School Board will implement procedures to verify vendors are not suspended, debarred or otherwise excluded.