Finding Text
Finding Number: 2023‐001
Repeat Finding: Yes, 2022‐001
Program Name/Assistance Listing Title: Indian School Equalization
Assistance Listing Number: 15.042
Federal Agency: U.S. Department of the Interior
Federal Award Number: A22AV00856
Pass‐Through Agency: Bureau of Indian Affairs
Questioned Costs: N/A
Type of Finding: Noncompliance, Material Weakness
Compliance Requirement: Procurement, Suspension and Debarment
Criteria
Non‐federal entities other than states, including those operating federal programs as subrecipients
of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326.
They must use their own documented procurement procedures, which reflect applicable State and
local laws and regulations, provided that the procurements conform to applicable federal statutes
and the procurement requirements identified in 2 CFR part 200.
Condition
Adequate internal controls over its procurement procedures to ensure compliance with federal
regulations and guidelines and School policies were not in place. The School did not establish
complete written procurement standards. In addition, 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 procurement.
Context
During our review of purchasing, we noted the following:
- Sealed bids were not performed in accordance with School policies. However, these
purchases did not rise above the Simplified Acquisition Threshold.
- For eight of 10 vendors reviewed with total expenditures below the Simplified Acquisition
threshold, no documentation of quotes was maintained.
- The School's policy did not include any language regarding quotes and thresholds.
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The School should develop and implement policies and procedures to ensure compliance with
federal procurement requirements.
Views of Responsible Officials
See Corrective Action Plan.