Finding 34137 (2022-001)

Finding 2022-001 Criteria: Federal uniform guidance under CFR 200.320 and Pennsylvania State School Code bid requirements have various thresholds for procurement procedures to be followed by all non-federal entities. The acquisition of goods and services must abide by the rules set by Federal and State guidance to ensure that they are purchased properly and responsibly. Condition and context: During the allowable cost testing of ESSER it was identified that a service consultant was utilized by the District. The service cost exceeded the ?Small Purchase Procedures? threshold of Uniform Guidance, which calls for at least 3 price or rate quotes from a reasonable number of qualified sources. The procurement policy established by the board is consistent with the various requirements, however, the District identified that this policy and procedure was not followed. Cause and effect: Although the internal controls over procurement exist and were circumvented in this situation, additional procurement tests were performed and determined the lapse was an isolated incident. The service cost in question was also allowable cost under the grant requirements. Recommendations: The District?s staff should adhere to the well-defined policy and procedures established by the District under Uniform Guidance and State regulations. Additional training for employees who are authorized to make purchases is recommended to ensure everyone who can authorize transactions follows all steps of the internal control process over disbursements.