Finding 395388 (2023-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-04-30

AI Summary

  • Core Issue: The Center did not follow required procurement procedures under the Uniform Guidance for federal funds, using noncompetitive procurement without proper documentation.
  • Impacted Requirements: Noncompliance with 2 CFR 200.318 and 200.320, which mandate documented procurement processes and formal methods for purchases exceeding the simplified acquisition threshold.
  • Recommended Follow-Up: Ensure compliance with procurement policies when using federal funds, document the procurement process, and maintain records with Federal Award budget documents.

Finding Text

Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023 Career and Technical Education - AL #84.048, Year Ended June 30, 2023 U.S. Department of Education Pass-Through Entity - Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The Center did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the Center made procurements through noncompetitive procurement arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, the Center could use noncompetitive procurement. The Center should consult with the Pennsylvania Department of Education before using this authority. Subsequently, the Center paid for this purchase utilizing the Education Stabilization Fund and Career and Technical Education monies. In using federal funds to pay for these items, the Center inadvertently did not follow its procurement policy. Cause and Effect: When the Center initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The Center did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: No Questioned Costs: None Recommendation: We recommend that when the Center decides to utilize cooperative purchasing programs or noncompetitive purchasing arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The Center should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: The Center acknowledges this finding, and has since revised its procurement process to include the requisite items as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made in response to the COVID-19 Pandemic, and with delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures

Corrective Action Plan

The Center did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the Center made procurements through noncompetitive procurement arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, the Center could use noncompetitive procurement. The Center should consult with the Pennsylvania Department of Education before using this authority. Subsequently, the Center paid for this purchase utilizing the Education Stabilization Fund and Career and Technical Education monies. In using federal funds to pay for these items, the Center inadvertently did not follow its procurement policy. Response and Planned Corrective Action: The Center acknowledges this finding, and has since revised its procurement process to include the requisite items as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made in response to the COVID-19 Pandemic, and with delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures. Planned Corrective Action: • When using federal funds, the Business Manager/Asst. Business Manager will ensure that cooperative purchasing programs or noncompetitive purchasing arrangements comply with the UGG procurement policy. • The Business Manager/Asst. Business Manager will document the process and how it complied with the procurement standards and keep such documentation with Federal Award budget/procurement documents.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 395387 2023-002
    Significant Deficiency
  • 395389 2023-002
    Significant Deficiency
  • 395390 2023-004
    Significant Deficiency
  • 395391 2023-002
    Significant Deficiency
  • 395392 2023-003
    Significant Deficiency
  • 395393 2023-004
    Significant Deficiency
  • 395394 2023-005
    Significant Deficiency
  • 395395 2023-005
    Significant Deficiency
  • 395396 2023-005
    Significant Deficiency
  • 395397 2023-005
    Significant Deficiency
  • 971829 2023-002
    Significant Deficiency
  • 971830 2023-004
    Significant Deficiency
  • 971831 2023-002
    Significant Deficiency
  • 971832 2023-004
    Significant Deficiency
  • 971833 2023-002
    Significant Deficiency
  • 971834 2023-003
    Significant Deficiency
  • 971835 2023-004
    Significant Deficiency
  • 971836 2023-005
    Significant Deficiency
  • 971837 2023-005
    Significant Deficiency
  • 971838 2023-005
    Significant Deficiency
  • 971839 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $490,958
84.048 Career and Technical Education -- Basic Grants to States $236,955
84.268 Federal Direct Student Loans $87,212
10.555 National School Lunch Program $45,521
10.649 Pandemic Ebt Administrative Costs $628
84.063 Federal Pell Grant Program $-24,910