Finding 35029 (2022-002)

Material Weakness
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2023-06-20

AI Summary

  • Core Issue: The District did not follow federal procurement rules by failing to obtain required quotes and bids for purchases over $10,000.
  • Impacted Requirements: Non-compliance with 2 CFR 200.318 led to questioned costs totaling $793,135 due to misunderstanding of cooperative purchasing programs.
  • Recommended Follow-up: Ensure adherence to procurement policies by obtaining three quotes or bids, documenting all decisions, and clarifying the use of cooperative purchasing programs.

Finding Text

Criteria - 2 CFR 200.318 A component of compliance relating to federal awards is maintaining records sufficient to detail the history of procurement. These records will include, but are not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition - The District used federal ESSER funds to make purchases greater than $10,000 to $21,900 without obtaining at least three quotes and made purchases greater than $21,900 without obtaining three public bids. Cause/Effect Cause of the Finding ? There was a breakdown in the previously established purchasing policy relating to obtaining quotes and bid requirements. In addition, the district was under the false notion that purchases made through the Commonwealth of Pennsylvania?s cooperative purchasing program COSTARS and PEPPM satisfied compliance requirement of quote/bid requirements for federal purchases. Effect of the Finding ? The District was not in compliance with procurement requirements for federal funds. Questioned Costs ? Total questioned costs - $793,135 - Purchases made under the false notion that PEPPM satisfied the three?quote requirement total $16,365 (2% of ESSERS expense), purchases made under the false notion that COSTAR satisfied the three-bid requirement total $401,962 (43% of ESSERS expense), and purchases that were made outside co-purchasing arrangements and did not satisfy three-bid requirement total $374,805 (40% of ESSERS expense). Recommendations - The Uniform Guidance establishes thresholds of when quote and bids are to be obtained from vendors. Documentation is key for all federal purchases. A purchase price from cooperative purchasing programs can be considered one competitive price proposal and cannot replace a procurement process. Advertise when appropriate, obtain adequate quote/bid information from three vendors, and thoroughly document the ?reason? and ?cost analysis? of sole source noncompetitive procurement exceptions. District?s Response - The district will follow the policy for quotation/bid requirements for federal purchases and not use cooperative purchasing programs as the only source of quotations/bids for federal purchases. The district will also improve documentation relating to purchases that meet sole source criteria.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 35018 2022-001
    Material Weakness
  • 35019 2022-002
    Material Weakness
  • 35020 2022-001
    Material Weakness
  • 35021 2022-002
    Material Weakness
  • 35022 2022-001
    Material Weakness
  • 35023 2022-002
    Material Weakness
  • 35024 2022-001
    Material Weakness
  • 35025 2022-002
    Material Weakness
  • 35026 2022-001
    Material Weakness
  • 35027 2022-002
    Material Weakness
  • 35028 2022-001
    Material Weakness
  • 611460 2022-001
    Material Weakness
  • 611461 2022-002
    Material Weakness
  • 611462 2022-001
    Material Weakness
  • 611463 2022-002
    Material Weakness
  • 611464 2022-001
    Material Weakness
  • 611465 2022-002
    Material Weakness
  • 611466 2022-001
    Material Weakness
  • 611467 2022-002
    Material Weakness
  • 611468 2022-001
    Material Weakness
  • 611469 2022-002
    Material Weakness
  • 611470 2022-001
    Material Weakness
  • 611471 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies $172,674
10.553 School Breakfast Program $117,850
10.555 National School Lunch Program $55,750
84.367 Improving Teacher Quality State Grants $30,956
84.424 Student Support and Academic Enrichment Program $11,734
10.649 Pandemic Ebt Administrative Costs $614
84.425 Education Stabilization Fund $413