Finding Text
Finding Criteria – 2 CFR 200.318(i) - 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. 200.320(a)(2)(i) - The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-chase 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 services as determined appropriate by the entity. Condition Found – The District used federal ESSER funds to make purchases greater than $10,000 to $22,500 without obtaining at least three quotes, made purchases greater than $22,500 and did not obtain at least three public bids, or adequate documentation for sole source procurement. Cause of the Finding – Unable to obtain and review sufficient documentation to verify that purchases were competitively procured such as quote/bid evaluation of three vendors, or sole source procurement.
Effect of the Finding – The District was not in compliance with procurement requirements for federal funds.
Questioned Costs – While expenditure meet eligibility of grant expenditures, the district did not obtain three quotes/bids to document competitive procurement. The district utilized ESSER funds to make twelve purchases totaling $279,041 that did not include the relevant elements such as date, rationale for method of procurement, basis, and reasonableness, to substantiate the purchase when utilizing sole source. Recommendations - Documentation is key for all federal purchases. Obtain adequate quote/bid information from three vendors, advertise when appropriate, and thoroughly document the “reason” and “cost analysis” of sole source noncompetitive procurement exceptions. A purchase price from cooperative purchasing programs can be considered one competitive price proposal and cannot replace a procurement process. Management's Response -The district will follow the policy for obtaining three quotation/bid requirements for federal purchases and improve documentation relating to purchases that meet sole source criteria. In the event purchases are made through cooperative purchasing programs, three quotes will be documented when federal purchases are made.