Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: IDEA Basic Local Assistance Entitlement, Part B, Section 611
Assistance Listing Number: 84.027
Pass-Through Agency: Placentia-Yorba Linda Unified School District
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of suspension and debarment. The District is required to verify that vendors selected for services are neither suspended nor debarred and should have a system internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the District did not verify that vendors were not suspended or debarred for 2 out of the 5 vendors tested. This was limited to vendors for services based on a student’s IEP where vendors are selected by the parent.
Questioned Costs: None. No vendors tested were suspended or debarred.
Context: There were a total of 10 vendors with contracts equaling or exceeding $25,000.
Cause: There was a misunderstanding of this federal compliance requirement by the District.
Effect: The auditor noted no instances of vendors identified as suspended or debarred; however, a lack of procedure and internal control could result in non-compliance.
Repeat Finding: No.
Recommendation: We recommend the District design procedures and controls to ensure an adequate review process is in place to determine vendors are not suspended or debarred.
Views of Responsible Officials and Planned Corrective Actions:
Record Retention Deficiency: Did not provided documentation for the requested suspension and debarment of two Special Education Contracts.
1. Business Department will work with the Special Education Department to add standard language into contracts to cover the certification requirements. Internal Control Deficiency: No procedure in place to determine if vendors paid for out of federal award funds are not on suspension and/or debarment list on SAM.gov.
Created an account on SAM.gov to have the ability to check current and new vendors with contracts over $25K to verify that they are not presently debarred or suspended.
Business Department will check each new and/or renewed contract for each vendor over $25K on SAM.gov, print a copy of the screen, and attach it to the Purchase Order.
The areas listed in the above Corrective Action Plan will be addressed and implemented immediately in the current fiscal year 2023-24.