Finding Text
CONDITION: The Western Beaver County School District contracted with two (2) third-party vendors – CCL Technologies and AVI-SPL LLC for the purchase of technology equipment. The contracts were procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the technology procurement contracts were competitively procured, such as a bid evaluation and public solicitation and 2) did not obtain the adequate number of price or rate quotations. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. CAUSE: School District personnel directly responsible for the oversight and execution of the technology contracts interpreted that the requirements specified by 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i), would be met through the cooperative purchasing, however the District appears to not have received and maintained all of the specific history of procurement documents internally, as referenced under the criteria section, to support this compliance. In addition, the District did not maintain documentation to substantiate that an adequate number of price quotations were solicited. EFFECT: The Western Beaver County School District did not comply with the requirements of 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, regarding maintaining records sufficient to detail the history of procurement for the technology equipment. In addition, the District did not comply with 24 PS 8.807.1 regarding maintaining documentation to substantiate that an adequate number of price quotations for the technology equipment. QUESTIONED COST: $152,796 (CCL Technologies), $121,290 (AVI-SPL LLC) RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, specifically Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i) of the Uniform Guidance. In addition, it is recommended that the District document its attempts to obtain an adequate number of price or rate quotations as specified by 24 PS 8.807.1 over the $10,000 expenditure threshold. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).