Finding 35496 (2022-003)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-26

AI Summary

  • Core Issue: The School Corporation lacked effective internal controls for procurement and vendor eligibility, leading to noncompliance with federal regulations.
  • Impacted Requirements: Failure to follow proper procurement procedures and verify vendor eligibility for federal assistance programs.
  • Recommended Follow-Up: Implement robust procurement policies and procedures, including oversight for obtaining price quotes and checking vendor eligibility against suspension and debarment lists.

Finding Text

FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 20-21, FY 21/22 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 19 METROPOLITAN SCHOOL DISTRICT OF WARREN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement The School Corporation had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchases were followed. There was no oversight, review, or approval process in place and documented at the School Corporation to ensure proper procedures were followed and price or rate quotations were obtained. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000 per Indiana Code. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for three vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micropurchase threshold. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. In addition, contracts were not awarded for the two vendors tested in fiscal year 2020-2021 with purchases exceeding $50,000. Suspension and Debarment The School Corporation had not designed or implemented adequate policies or procedures to ensure that applicable vendors who received federal funds were not suspended or debarred from participating in federal awards programs. Nonfederal entities and contractors are subject to non-procurement debarment and suspension regulations. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or are ineligible for participation in Federal assistance programs or activities. This is done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. There were three vendors subject to suspension and debarment requirements during the audit period. The School Corporation did not perform procedures to ensure the vendors were not suspended, debarred, or otherwise excluded from or eligible for participation in Federal assistance programs or activities. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 20 METROPOLITAN SCHOOL DISTRICT OF WARREN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." INDIANA STATE BOARD OF ACCOUNTS 21 METROPOLITAN SCHOOL DISTRICT OF WARREN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed nor implemented an effective system of internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 35480 2022-002
    Material Weakness
  • 35481 2022-003
    Material Weakness
  • 35482 2022-004
    Material Weakness
  • 35483 2022-002
    Material Weakness
  • 35484 2022-003
    Material Weakness
  • 35485 2022-004
    Material Weakness
  • 35486 2022-002
    Material Weakness
  • 35487 2022-003
    Material Weakness
  • 35488 2022-004
    Material Weakness
  • 35489 2022-002
    Material Weakness
  • 35490 2022-003
    Material Weakness
  • 35491 2022-004
    Material Weakness
  • 35492 2022-002
    Material Weakness
  • 35493 2022-003
    Material Weakness
  • 35494 2022-004
    Material Weakness
  • 35495 2022-002
    Material Weakness
  • 35497 2022-004
    Material Weakness
  • 35498 2022-002
    Material Weakness
  • 35499 2022-003
    Material Weakness
  • 35500 2022-004
    Material Weakness
  • 35501 2022-002
    Material Weakness
  • 35502 2022-003
    Material Weakness
  • 35503 2022-004
    Material Weakness
  • 35504 2022-006
    Material Weakness
  • 35505 2022-006
    Material Weakness
  • 35506 2022-005
    Material Weakness
  • 35507 2022-007
    Material Weakness
  • 35508 2022-005
    Material Weakness
  • 35509 2022-007
    Material Weakness
  • 611922 2022-002
    Material Weakness
  • 611923 2022-003
    Material Weakness
  • 611924 2022-004
    Material Weakness
  • 611925 2022-002
    Material Weakness
  • 611926 2022-003
    Material Weakness
  • 611927 2022-004
    Material Weakness
  • 611928 2022-002
    Material Weakness
  • 611929 2022-003
    Material Weakness
  • 611930 2022-004
    Material Weakness
  • 611931 2022-002
    Material Weakness
  • 611932 2022-003
    Material Weakness
  • 611933 2022-004
    Material Weakness
  • 611934 2022-002
    Material Weakness
  • 611935 2022-003
    Material Weakness
  • 611936 2022-004
    Material Weakness
  • 611937 2022-002
    Material Weakness
  • 611938 2022-003
    Material Weakness
  • 611939 2022-004
    Material Weakness
  • 611940 2022-002
    Material Weakness
  • 611941 2022-003
    Material Weakness
  • 611942 2022-004
    Material Weakness
  • 611943 2022-002
    Material Weakness
  • 611944 2022-003
    Material Weakness
  • 611945 2022-004
    Material Weakness
  • 611946 2022-006
    Material Weakness
  • 611947 2022-006
    Material Weakness
  • 611948 2022-005
    Material Weakness
  • 611949 2022-007
    Material Weakness
  • 611950 2022-005
    Material Weakness
  • 611951 2022-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund Fy 22 $777,219
10.555 National School Lunch Program Fy 22 $722,964
10.555 National School Lunch Program Fy 21 $495,984
84.027 Special Education_grants to States Fy 22 $381,477
84.027 Special Education_grants to States Fy 21 $293,450
10.559 Summer Food Service Program for Children Fy 21 $231,205
84.010 Title I Grants to Local Educational Agencies Fy 22 $199,177
10.553 School Breakfast Program Fy 22 $179,959
84.010 Title I Grants to Local Educational Agencies Fy 21 $157,451
84.002 Adult Education - Basic Grants to States Fy 22 $156,565
10.553 School Breakfast Program Fy 21 $131,614
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) Fy 21 $101,500
84.425 Education Stabilization Fund Fy 21 $92,500
10.559 Summer Food Service Program for Children Fy 22 $69,312
84.367 Improving Teacher Quality State Grants Fy 22 $38,972
93.778 Medical Assistance Program Fy 21 $37,607
84.048 Career and Technical Education -- Basic Grants to States Fy 21 $30,406
84.367 Improving Teacher Quality State Grants Fy 21 $30,305
84.048 Career and Technical Education -- Basic Grants to States Fy 22 $24,594
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) Fy 22 $16,529
93.778 Medical Assistance Program Fy 22 $14,806
84.173 Special Education_preschool Grants Fy 22 $11,213
84.173 Special Education_preschool Grants Fy 21 $11,027
84.424 Student Support and Academic Enrichment Program Fy 22 $6,675
84.424 Student Support and Academic Enrichment Program Fy 21 $5,750
84.002 Adult Education - Basic Grants to States Fy 21 $4,270
21.019 Coronavirus Relief Fund Fy 21 $1,425
10.649 Pandemic Ebt Administrative Costs Fy 22 $614