Finding 39073 (2022-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-30
Audit: 46473
Organization: North Newton School Corporation (IN)
Auditor: Crowe LLP

AI Summary

  • Core Issue: The School Corporation lacked effective internal controls for procurement and suspension/debarment compliance, leading to material noncompliance with federal requirements.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303 and 2 CFR 200.320 regarding procurement processes and ensuring vendors are not suspended or debarred.
  • Recommended Follow-Up: Management should implement robust internal controls to ensure compliance with grant agreements and procurement regulations, as outlined in their corrective action plan.

Finding Text

FINDING 2022-001 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01, 19619-49-PN01, 20619-047-PN01, 20611-049-PN01, 21611-047-PN01, 20619-49-PN01, 21619-047- PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) " 2 CFR 200.303 states: ?When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: 1. Checking SAM Exclusions; or 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person.? 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement? ?(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited, and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply " Condition: The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement ? Simplified Acquisition The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions. The Cooperative did not have adequate procedures in place to ensure procurements for simplified acquisitions were properly advertised and bids accepted. There were two vendors who met the Simplified Acquisition threshold during the audit period; neither were properly procured. Suspension and Debarment The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the Suspension and Debarment requirements. During school year 2020, the Cooperative did not have adequate procedures in place to ensure that applicable vendors who received federal funds were not suspended or debarred from participation in federal awards programs. There were three contracted vendors during the audit period; the unit did not perform procedures to ensure the vendors were not excluded or disqualified. During the 2021 school year, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls and noncompliance related to procurement were isolated to school year 2020-2021. The lack of controls related to suspension and debarment were systemic throughout the audit period; however, the noncompliance was isolated to school year 2020-2021. Cause: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the procurement requirements for simplified acquisitions or suspension and debarment requirements for all contracts. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 39068 2022-001
    Material Weakness
  • 39069 2022-001
    Material Weakness
  • 39070 2022-001
    Material Weakness
  • 39071 2022-001
    Material Weakness
  • 39072 2022-001
    Material Weakness
  • 39074 2022-001
    Material Weakness
  • 39075 2022-001
    Material Weakness
  • 39076 2022-004
    Significant Deficiency
  • 39077 2022-002
    Material Weakness
  • 39078 2022-003
    Material Weakness
  • 39079 2022-004
    Significant Deficiency
  • 39080 2022-002
    Material Weakness
  • 39081 2022-003
    Material Weakness
  • 39082 2022-004
    Significant Deficiency
  • 39083 2022-004
    Significant Deficiency
  • 615510 2022-001
    Material Weakness
  • 615511 2022-001
    Material Weakness
  • 615512 2022-001
    Material Weakness
  • 615513 2022-001
    Material Weakness
  • 615514 2022-001
    Material Weakness
  • 615515 2022-001
    Material Weakness
  • 615516 2022-001
    Material Weakness
  • 615517 2022-001
    Material Weakness
  • 615518 2022-004
    Significant Deficiency
  • 615519 2022-002
    Material Weakness
  • 615520 2022-003
    Material Weakness
  • 615521 2022-004
    Significant Deficiency
  • 615522 2022-002
    Material Weakness
  • 615523 2022-003
    Material Weakness
  • 615524 2022-004
    Significant Deficiency
  • 615525 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $893,095
84.425 Covid-19 - Education Stabilization Fund $260,557
10.553 School Breakfast Program $224,678
84.027 Special Education_grants to States $170,016
84.010 Title I Grants to Local Educational Agencies $99,058
84.367 Supporting Effective Instruction State Grants $35,862
10.579 Child Nutrition Discretionary Grants Limited Availability $12,000
84.424 Student Support and Academic Enrichment Program $6,417
93.778 Medical Assistance Program $5,203
84.173 Special Education_preschool Grants $1,168
10.649 Covid-19 - Pandemic Ebt Administrative Costs $614