Finding Text
FINDING 2023-003 – PROCUREMENT AND SUSPENSION AND DEBARMENT
(Repeat Finding of 2022-003)
Significant Deficiency
Federal Programs: Charter Schools – AL 84.282
Repeat Finding: This is a repeat finding from the immediately prior audit report. The prior audit finding
number was 2022-003.
Criteria
2 CFR 200.318(i) establishes the need to maintain records sufficient to detail the history of procurement. 2
CFR 180.300 establishes the responsibilities of participants entering into covered transactions.
Condition
The Organization lacked sufficient documentation to support the rationale of procurement methods,
selection of contract types, contractor selection or rejection, and basis for the contract price. We also noted
suspension and debarments requirements were not given consideration prior to entering into these
transactions. However, we noted there were adequate invoices to support the purchases.
Cause and Effect
As described in 2023-001, the Organization has not established a formal process related to federal awards
to identify all key compliance requirements and changes in compliance requirements, evaluate risks of
noncompliance with these requirements, and respond to such risks of noncompliance through establishing
or changing processes and internal controls. Additionally, certain individuals, within a department,
responsible for the use of federal funds lacked knowledge of the compliance requirements pertaining to the
use of the funds. As a result, they did not comply with requirements for proper procurement or in relation
to suspension and debarment.
Recommendation
We recommend the Organization develop a system of internal controls aligned with the applicable
compliance requirements to sufficiently document procurements and to ensure suspension and debarment
is considered prior to entering into future covered transactions.
Views of Responsible Officials and Planned Corrective Actions
The Organization’s Corrective Action Plan is included on pages 43 and 44.