Finding 38518 (2022-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-27
Audit: 36719
Organization: Gila Crossing Community School (AZ)

AI Summary

  • Core Issue: The School failed to verify that vendors receiving over $25,000 in federal funds were not suspended or debarred, violating federal procurement regulations.
  • Impacted Requirements: Non-compliance with procurement and suspension/debarment guidelines as outlined in 2 CFR §180.220 and §200.320.
  • Recommended Follow-Up: Review and implement documented procurement policies to ensure compliance with federal requirements moving forward.

Finding Text

FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR ?200.320. CONDITION Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. CAUSE The School?s internal controls over procurement of goods and services were not adequate. EFFECT The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. CONTEXT The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to three vendors. Additionally, for three of four vendors paid between $25,000 to $100,000, the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. RECOMMENDATION The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 38514 2022-001
    Significant Deficiency Repeat
  • 38515 2022-002
    Significant Deficiency
  • 38516 2022-003
    Significant Deficiency
  • 38517 2022-001
    Significant Deficiency Repeat
  • 38519 2022-003
    Significant Deficiency
  • 38520 2022-003
    Significant Deficiency
  • 38521 2022-003
    Significant Deficiency
  • 614956 2022-001
    Significant Deficiency Repeat
  • 614957 2022-002
    Significant Deficiency
  • 614958 2022-003
    Significant Deficiency
  • 614959 2022-001
    Significant Deficiency Repeat
  • 614960 2022-002
    Significant Deficiency
  • 614961 2022-003
    Significant Deficiency
  • 614962 2022-003
    Significant Deficiency
  • 614963 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
15.042 Indian School Equalization Program $2.89M
84.010 Title I Grants to Local Educational Agencies $753,002
15.046 Administrative Cost Grants for Indian Schools $731,373
10.559 Summer Food Service Program for Children $611,306
84.027 Special Education_grants to States $502,953
15.047 Indian Education Facilities, Operations, and Maintenance $441,464
84.425 Covid-19 Education Stabilization Fund $297,715
15.043 Indian Child and Family Education $289,684
84.287 Twenty-First Century Community Learning Centers $131,798
15.044 Indian Schools_student Transportation $126,767
84.060 Indian Education_grants to Local Educational Agencies $81,931
15.151 Education Program Enhancements $66,824
84.371 Comprehensive Literacy Development $61,956
32.009 Covid-19 Emergency Connectivity Fund Program $59,140
15.042 Covid-19 Indian School Equalization Program $31,609
84.336 Teacher Quality Partnership Grants $4,401