Finding Text
Finding Number: 2022-003 Repeat Finding: Similar to prior year finding 2021-002 Program Name/Assistance Listing Title: Indian School Equalization Program, Special Education Cluster Assistance Listing Number: 15.042, 84.027 Federal Agency: U.S. Department of the Interior, U.S. Department of Education Federal Award Number: A19AV00847 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Procurement, Suspension and Debarment Criteria: Under 2 CFR ?215.43 the School is required to implement certain procurement policies that adhere to the minimum federal requirements as outlined in 2 CFR ?215.44. Non-federal entities other than States, including those operating federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the Procurement requirements identified in 2 CFR part 200. Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?80.220. Condition: The School did not always follow procurement standards as put forth in 2 CFR ?200.318 through ?200.326. In addition, the School did not verify that covered transactions were made only to entities that were not suspended or debarred or otherwise excluded. Effect: Noncompliance with federal regulation that led to a qualified audit opinion over the listed federal programs as noted above. Cause: Management oversight. Context: For two of 2 vendors in the Formal Procurement Threshold reviewed, the School did not maintain documentation that appropriate procurement procedures were performed. Additionally, for twenty-four of 29 vendors within the Simplified Acquisition Threshold reviewed, the School did not maintain documentation that appropriate procurement procedures were performed. Finally, for four of 21 vendors with at least $25,000 in purchases reviewed, the School did not maintain documentation that a current suspension and debarment check was performed. Recommendation: The School should review its procurement procedures to ensure that proper procurement procedures are performed documentation is maintained to support the procurement. Response: The School concurs with this recommendation and will implement procedures to ensure compliance with federal regulation. Contact person: Dolores Baluyut, Business Manager