Finding Text
Finding Criteria – 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 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. Condition Found – The District used federal ESSER funds to make eligible grant purchases greater than $22,500 and did not obtain/document at least three public bids. Cause of the Finding – The District was under the false notion that purchases made through the Commonwealth of Pennsylvania’s cooperative purchasing program COSTARS 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 – Purchases made under the false notion that COSTARS satisfied three-bid requirement total $44,619 (2% of total ESSERS expense). Recommendations - 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. Management’s Response - The district will follow the policy for quotation/bid requirements for federal purchases made by the district and when cooperative purchasing programs are utilized. The district will continue to thoroughly document purchases that meet sole source criteria.