Finding 391256 (2023-003)

Federal Agency: U.S. Department of Education Federal Programs: Teacher and School Leader Incentive Grants Assistance Listing Number: 84.374A Federal Award Identification Number and Year: S374A200032-22 Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: October 1, 2020 – September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Recipients are expected to comply with suspension and debarment standards set out in 2 CFR section 180 within Uniform Guidance. Condition: For 3 of 3 procurement transaction selected for testing, the School Department could not provide appropriate written documentation that suspension and debarment policies and procedures were followed. Questioned Costs: None Cause: The School Department has policies and procedures for obtaining appropriate written documentation that vendors are not suspended or debarred, but these procedures were not retrospectively applied to grant funded contracts entered into before the policies were implemented. Effect: The City may enter into a transaction with an entity who is suspended or debarred. Recommendation: We recommend that the City retrospectively apply procedures to grant funded contracts entered into before policies were implemented to ensure vendors are not suspended or debarred. Views of Responsible Officials: Management concurs with this finding.