Finding 366812 (2023-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-02-12

AI Summary

  • Core Issue: Significant deficiency in procurement practices; 9 out of 25 transactions over $10,000 did not follow local policies.
  • Impacted Requirements: Nonprofit organizations must ensure full competition and obtain competitive quotes as per federal and state laws.
  • Recommended Follow-Up: Update procurement policies to align with internal practices and ensure compliance with competitive procurement procedures.

Finding Text

Finding #2023-002 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Education Agency, Child Nutrition Cluster, Assistance Listing #: 10.553, 10.555, Contract Number: 71402101, 71402201, 71302101, 71302201, Contract Years: 10/01/21 – 9/30/22 and 10/01/22 – 9/30/23. U. S. Department of Education, Passed through Texas Education Agency, Special Education Cluster, Assistance Listing #: 84.027A, 84.173A, 84.173X, Contract Number: H027A210008 H173A210004, H173X210004, Contract Years: 07/08/21 – 9/30/22 and 07/01/22 – 9/30/23. Criteria: Procurement – Nonprofit organizations are required to conduct procurement transactions in a manner providing full and open competition consistent with standards prescribed in Uniform Guidance, Procurement Standards, and the Texas Education Code, Section 12.1053, and conform to federal and state laws and regulations and other contractual requirements. Uniform Guidance and the Texas Education Code require obtaining competitive quotes for purchases over the Micro-purchase Threshold, as defined by the nonprofit organization’s written policy, which is $10,000 for Austin Achieve. Condition and context: During our testing of procurement documents for 25 purchases, we noted that 9 transactions tested in excess of $10,000 were not procured in accordance with Austin Achieve’s local written procurement policies. These purchases were charged to the Texas Education Agency – Foundation School Program. Cause: The formal written procurement policies had not been updated to conform with internal procurement practices. Effect: Failure to follow procurement policies may result in Austin Achieve purchasing goods or services for more than would be necessary if required competitive procurement procedures had been followed. Questioned costs: None. Recommendation: Same as finding #2023-001. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Finding #2023-002 – Significant Deficiency. Recommendation: Formally adopt written procurement policies that are updated for current practices. Planned corrective action: The contracted outside accounting service had fiduciary oversight per the adopted bylaws in effect for fiscal year 2023 and was responsible for submitting the application to the state for the higher procurement threshold of $49,999. Threshold increases had been previously requested and granted annually as recently as fiscal year 2022. The Board and management discovered during the audit that the previous outside accounting service had not submitted an application for the higher $49,999 threshold to the TEA, as allowed and as expected. Lack of transparency from the previous accounting service created a scenario in which Austin Achieve was unaware of the lower $10,000 procurement threshold and, as a result, was unable to adjust local procurement policies to comply. Upon discovery of the previous accounting service’s non actions regarding submission for the intended procurement threshold and the review of the correct written policies with the Board, the management of Austin Achieve applied and was approved for the $49,999 threshold by the TEA for the fiscal year 2024. Management has already presented the Board with updated procurement policies during the September 19, 2023 Board meeting. These policies were approved by the Board. In addition, management has reviewed the updated policies with the members of the executive team who oversee budget authority for each of their respective departments. Responsible officer: Chief Financial Officer, Angie Bealko. Estimated completion date: September 30, 2023

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 366813 2023-002
    Significant Deficiency
  • 366814 2023-002
    Significant Deficiency
  • 366815 2023-002
    Significant Deficiency
  • 366816 2023-002
    Significant Deficiency
  • 366817 2023-002
    Significant Deficiency
  • 943254 2023-002
    Significant Deficiency
  • 943255 2023-002
    Significant Deficiency
  • 943256 2023-002
    Significant Deficiency
  • 943257 2023-002
    Significant Deficiency
  • 943258 2023-002
    Significant Deficiency
  • 943259 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.558 Child and Adult Care Food Program $1.17M
10.553 School Breakfast Program $1.00M
84.010 Title I Grants to Local Educational Agencies $847,102
94.006 Americorps $476,406
84.367 Improving Teacher Quality State Grants $113,888
84.365 English Language Acquisition State Grants $97,502
84.424 Student Support and Academic Enrichment Program $65,509
84.027 Special Education_grants to States $54,905
10.555 National School Lunch Program $31,152
84.173 Special Education_preschool Grants $8,497
84.425 Education Stabilization Fund $7,627