Finding Text
Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Assistance Listing Number and Title: 84.027 ? Special Education Grants to States 84.027 ? COVID-19 ? Special Education Grants to States 84.173 ? Special Education ? Preschool Grants 84.173 ? COVID-19 ? Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Description of Condition During the 2021-2022 school year, the District spent $1,029,182 in Special Education program funds. The objective of the Special Education program is to help education agencies provide special education and related services to all children with disabilities. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established program controls. Federal regulations also require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Federal regulations and District policy require the District to obtain price or rate quotes from an adequate number of sources for any services more than $10,000 but less than $250,000. For personal service contracts more than $250,000, the District must solicit sealed bids or competitive proposals. The District must also keep records to demonstrate compliance with these requirements. The District paid $345,952 and $65,860 for two personal service contracts using federal funds. Our audit found the District did not follow federal requirements and its own policy to procure personal services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior. Cause of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Effect of Condition The District cannot demonstrate it received the best price for the services purchased and is not in compliance with federal requirements. Recommendation We recommend the District establish internal controls to ensure it follows the most restrictive procurement procedures when using federal funds to procure goods or services. Further, we recommend the District ensure it maintains documentation necessary to demonstrate compliance with these procurement requirements. District?s Response The district made best effort attempts to comply with the procurement guidance and has made changes in the process to fully comply in the future. Auditor?s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Section 319 ? Competition, establishes all procurement transactions are to be conducted in a manner providing full and open competition, and requires non-federal entities to have written procedures for procurement transactions. Title 2 CFR Part 200, Section 320 ? Methods of procurement to be followed, describes each allowable procurement method.