Finding 371421 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-03-01
Audit: 293099
Auditor: Donovan PC

AI Summary

  • Core Issue: The School did not document price comparisons for small purchases between $10,000 and $249,999, violating federal procurement standards.
  • Impacted Requirements: This finding breaches 2 CFR 200.318 and 2 CFR 200.320(a)(2)(i), which require documented procurement procedures and price quotations from qualified sources.
  • Recommended Follow-Up: The School should establish and implement procedures to ensure that price comparisons are consistently obtained and documented for compliance.

Finding Text

FINDING 2023-001 PROCUREMENT SIGNIFICANT DEFICIENCY Federal Program: Charter School Facilities Incentive Program Assistance Listing Numbers: 84.282 Criteria Per 2 CFR 200.318, “The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §200.317 through 200.327.” Per 2 CFR 200.320(a)(2)(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.” Condition The School was unable to provide documentation to support that price comparisons were obtained from vendors for costs falling in the category of small purchases (between $10,000 and $249,999). Cause Documentation was not maintained to support that this step in the procurement process was completed. Effect Not documenting these procedures could result in the School completing procurement transactions not in compliance with Federal regulations. Recommendation We recommend the School develop procedures to ensure price comparisons are obtained and documented. Views of Responsible Officials and Planned Corrective Actions The School’s Corrective Action Plan is included on page 23.

Corrective Action Plan

This document serves as the response to the 2022-2023 Financial Audit on behalf of BELIEVE Schools, Inc. We’ve identified and reviewed the finding outlined below: The results of our auditing procedures disclosed one instance of noncompliance which is required to be reported in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) and which is described in the accompanying schedule of findings and questioned costs as Finding No. 2023- 001. Our opinion on the major federal programs is not modified with respect to these matters. In an effort to address the finding and to ensure the school's alignment with federal compliance standards, the following corrective action plan has been implemented for all purchases made with federal and state program funds: 1. For any procurement or contract ranging from $10,000-$250,000, The Principal, Angel Jackson-Anderson, should seek to acquire as many quotes as possible, aiming for up to five. Prior to finalizing any purchase order, invoice, or commencement of production, the school is mandated to receive and assess three price comparisons from different businesses or organizations. These price comparisons must be logged in the BCCHS Quote Comparison Template and reviewed by the following parties: a. The individual conducting the price comparison b. Building Level Operations Leader c. Executive Director for purchases or contracts exceeding $20,000 2. For any purchase or contract exceeding $250,000, a formal bidding process is required. BELIEVE Schools has adopted resources provided by the Indiana Department of Education: a. Procurement Checklist b. Procurement Plan Template (accessible through DOE) This protocol has been incorporated into the Standard Operating Procedures and School Handbooks, with all relevant stakeholders duly informed on February 16th, 2024.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 371422 2023-001
    Significant Deficiency
  • 947863 2023-001
    Significant Deficiency
  • 947864 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $143,405
84.010 Title I Grants to Local Educational Agencies $105,706
84.425 Education Stabilization Fund $51,414
10.553 School Breakfast Program $33,243
84.282 Charter Schools $29,247
84.424 Student Support and Academic Enrichment Program $10,000
16.839 Stop School Violence $7,813
84.367 Improving Teacher Quality State Grants $3,057
84.027 Special Education_grants to States $2,012