Finding 42552 (2022-001)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-01-07

AI Summary

  • Core Issue: The School failed to use the correct procurement method for a contract exceeding $25,000, violating financial policies.
  • Impacted Requirements: Non-compliance with 2 CFR §200.320, which mandates formal procurement methods for contracts above the simplified acquisition threshold.
  • Recommended Follow-Up: Establish a monitoring process for vendors with contracts over $20,000 to ensure compliance with procurement thresholds.

Finding Text

Finding 2022-001 U. S. Department of Education 84.370C ? DC Opportunity Scholarship Program Significant Deficiency over Compliance and Internal Control over Procurement and Suspension and Debarment Repeat Finding: Yes Condition: For 1 out of 1 selections, management did not follow the appropriate method of procurement for contracts in excess of $25,000, in accordance with the Schools financial policies and procedures and as set forth by the DC PCSB. Criteria: In accordance with 2 CFR ?200.320: When the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold (SAT), or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319. Cause: The contract was initially budgeted to be under $25,000 and was procured using small purchase procedures; however the total contract costs were $25,600 (which is greater than the School?s SAT) for the year ended June 30, 2022. Effect: The subrecipient may not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend the School implement a process to monitor its vendors that are above $20,000, to ensure year to date costs do not exceed $25,000. Auditee Response and Corrective Action Plan: Refer to the corrective action plan. Auditor?s Conclusion: Finding remains as stated.

Corrective Action Plan

December 14, 2022 Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 Finding 2022-001 U.S. Department of Education 84.370C- DC Opportunity Scholarship Program Significant Deficiency over Compliance and Internal Control over Procurement and Suspension and Debarment Planned Corrective Action: In response to last year's finding the School did implement more stringent procurement processes which include requiring the completion of a Grants Compliance Checklist prior to any spending on a federal grant. This was completed in the case of this vendor and demonstrated evidence of utilizing the simplified acquisition threshold (SAT) process was provided. However, we underestimated the amount we would spend on the the vendor. In our weekly accounting meeting, the School has implemented a process to monitor its vendors that have exceeded $20,000, to ensure year to data costs do not exceed $25,000. Beginning in September 2021, the School provided individual training to all budget managers which highlights federal and local procurement processes. We have also implemented quarterly meetings with all budget managers to ensure we are aware of upcoming expenses that may exceed the $25K threshold and/or incremental expenses that may exceed $25K with one vendor. Finally, we are proactively bidding out all contracts that exceeded $25K last year. Name of Contact Person: Tiffany Godbout, COO, 202-269-6623, tiffany@aohdc.org Anticipated completion date: The Corrective Action Plan will be implemented no later than January 1, 2023.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 42553 2022-001
    Significant Deficiency Repeat
  • 42554 2022-001
    Significant Deficiency Repeat
  • 618994 2022-001
    Significant Deficiency Repeat
  • 618995 2022-001
    Significant Deficiency Repeat
  • 618996 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.370 Soar- Formula Combined $376,439
84.370 Soar-Cares Combined (esser Iii) $201,588
21.027 Coronavirus Stated and Local Fiscal Recovery- Pcs Reopening Facilities $181,818
84.002 Afe- Federal $104,821
84.370 Soar-Cares Combined (academic Quality) $81,494
93.323 Covid-19 School Based Testing $58,219