Finding Text
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.