Finding Text
CONDITION: The Northern Cambria School District contracted with three (3) third-party vendors - Advanced Office Systems, Inc. for the purchase of copier equipment, Acorns to Oaks Consulting, LLC for professional emotional support services, and McGraw-Hill Education for educational materials. The contract with Advanced Office Systems, Inc. was procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the copier procurement contract was competitively procured, such as a bid evaluation and public solicitation, 2) did not obtain the adequate number of price or rate quotations for the professional emotional support services, and 3) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. CAUSE: School District personnel directly responsible for the oversight and execution of the copier contract interpreted that the requirements specified by 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i), would be met through the cooperative purchasing, however the District appears to not have received and maintained all of the specific history of procurement documents internally, as referenced under the criteria section, to support this compliance. In addition, the District did not 1) maintain documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services, and 2) did not properly document that the education material was from a sole source provider, and accordingly competitive procurement procedures would not apply. EFFECT: The Northern Cambria School District did not comply with the requirements of 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, regarding maintaining records sufficient to detail the history of procurement for the copiers, and to document instances where there is a sole source provider such as would be required for the educational materials. In addition, the District did not comply with 24 PS 8.807.1 regarding maintaining documentation to substantiate that an adequate number of price quotations were solicited for professional emotional support services. QUESTIONED COST: $134,156 (Advanced Office Systems-$26,851) (Acorns to Oaks Consulting, LLC-$33,890) (McGraw-Hill Education-$73,415) RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, specifically Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i) of the Uniform Guidance. In addition, it is recommended that the District document its attempts to obtain an adequate number of price or rate quotations as specified by 24 PS 8.807.1 over the $10,000 expenditure threshold, as well as document instances whereby the District is using a sole source provider and accordingly competitive procurement procedures would not apply. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).