Finding 44815 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2022-11-22

AI Summary

  • Core Issue: The District failed to keep a formal record of price comparisons for a procurement over $250,000, violating procurement requirements.
  • Impacted Requirements: The District must perform cost analysis and retain documentation for all purchases exceeding the Simplified Acquisition Threshold to ensure compliance with federal funding guidelines.
  • Recommended Follow-Up: Implement a system to retain procurement documentation and conduct price analysis for all purchases over $10,000 to prevent future deficiencies.

Finding Text

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER PROCUREMENT ? STATE AND LOCAL FISCAL RECOVERY FUNDS Condition: During our audit we noted no formal record was retained of a comparison of rates or prices to other emotional health services for a procurement purchase over the threshold of $250,000. Criteria or Specific requirement: The District should have controls in place to ensure compliance with procurement requirements of the State and Local Fiscal Recovery Fund program. This includes approving all purchases and performing a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Effect: Lack of proper procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The District could also possibly award a contract to a vendor that would charge more than other responsible bidders due to not having performed cost analysis. Cause: The vendor has been utilized by the District for over ten years as a professional service. The District recently charged it to federal funds to supplant some of their other costs. The District was unable to locate the original documents for the contract to determine if they were still under a professional services contract or not, and was not able to come up with any other type of documentation showing the required cost analysis. Questioned Costs: $50,000 Context: One of the five contracts tested did not have supporting documentation following procurement guidelines. Recommendation: We recommend that the District ensures it retains documentation of its controls over all procurements going forward. We also recommend that the district keep documentation of price analysis for procurement items over the micro purchase threshold of $10,000. Prior Year Finding? No Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Board of Education Independent School District No. 191 respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 to June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT FINDINGS None noted FINDINGS?FEDERAL AWARD PROGRAMS AUDITS Significant Deficiency in Internal in Internal Control over Procurement Recommendation: We recommend that the District ensures it retains documentation of its controls over all procurements going forward. We also recommend that the district keep documentation of price analysis and final determination for procurement items over the micro purchase threshold of $10,000. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will immediately implement the recommendation. Names of the contact persons responsible for corrective action: Tyler Dehne, Director of Finance Planned Completion date for corrective action plan: 6/30/2023

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 44816 2022-001
    Significant Deficiency
  • 44817 2022-001
    Significant Deficiency
  • 44818 2022-001
    Significant Deficiency
  • 621257 2022-001
    Significant Deficiency
  • 621258 2022-001
    Significant Deficiency
  • 621259 2022-001
    Significant Deficiency
  • 621260 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies $2.07M
10.553 School Breakfast Program $1.42M
84.367 Supporting Effective Instruction $475,180
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $467,480
10.555 National School Lunch Program $433,403
84.027 Special Education_grants to States $427,339
32.009 Emergency Connectivity Fund Program $274,480
84.365 English Language Acquisition State Grants $252,701
10.559 Summer Food Service Program for Children $247,592
84.048 Career and Technical Education -- Basic Grants to States $105,679
84.425 Education Stabilization Fund $97,317
21.027 Coronavirus State and Local Fiscal Recovery Funds $90,624
84.424 Student Support and Academic Enrichment Program $90,396
84.002 Adult Education - Basic Grants to States $68,482
84.206 Javits Gifted and Talented Students Education $62,487
84.181 Special Education-Grants for Infants and Families $55,380
10.582 Fresh Fruit and Vegetable Program $52,369
10.558 Child and Adult Care Food Program $46,722
84.173 Special Education_preschool Grants $37,148
84.196 Education for Homeless Children and Youth $30,653
84.060 Indian Education_grants to Local Educational Agencies $11,428
10.649 Pandemic Ebt Administrative Costs $7,284