Finding 47737 (2022-001)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-02-22

AI Summary

  • Core Issue: The District lacks documented internal controls for procurement and suspension/debarment, leading to non-compliance with federal guidelines.
  • Impacted Requirements: Failure to follow CFR Title 2 regulations means expenses over the micro-purchase threshold were not properly vetted.
  • Recommended Follow-Up: The Board should create and document procurement policies, regularly review federal guidelines, and ensure staff training on compliance.

Finding Text

U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Special Education Cluster (IDEA) Federal Assistance Listing Numbers: 84.027; 84.173 Finding 2022-001 SIGNIFICANT DEFICENCY Internal Controls Criteria: Pursuant to the Code of Federal Regulations (CFR), Title 2 Grants and Agreements, Subpart D Post Federal Award Requirements, Section 200.318 ?the non-federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property and services required under a Federal award or subaward.? Condition: The internal controls related to procurement and suspension and debarment are non-existent. Cause: The District does not have a written policy for procurement and suspension and debarment. Effect: Staff was unaware of the federal guidelines related to procurement and suspension and debarment. Expenses that happened over the micro-purchase threshold did not undergo the additional procedures before purchase. Recommendations: The Board of Directors, the Director and key positions of management should adequately document internal control procedures relating to procurement and suspension and debarment and adopt board policies related to such. The Board should then periodically check for changes in federal guidelines and update the board policy and needed. Views of Responsible Officials and Planned Corrective Actions: The Cooperative agrees with the finding. See separate document for planned corrective actions.

Corrective Action Plan

CORRECTIVE ACTION PLAN November 11, 2022 Kansas State Department of Education and Kansas State Department of Administration High Plains Educational Cooperative, District Number 611 respectfully submits the following corrective action plan for the year ended June 30, 2022. Dirks, Anthony & Duncan, LLC Po Box 885 Ulysses, KS 67880 Audit Period: June 30, 2022 FINDINGS ? FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027; 84.173 Finding 2022-001 ? Internal Controls Recommendations: The Board of Directors, the Director and key positions of management should adequately document internal control procedures relating to procurement and suspension and debarment and adopt board policies related to such. The Board should then periodically check for changes in federal guidelines and update the board policy and needed. Action Taken: We agree with the recommendation and will adopt the board policies at the next meeting. We will also have a meeting to enhance and document stronger internal controls with board members, the Director, Board Treasurer, Technology Facilitator and Finance Clerk. Our targeted implementation date is March 2023. If the Kansas State Department of Education and/or Kansas State Department of Administration has questions regarding this plan, please call Shelly Harris at 620-356-5577. Sincerely yours, Shelly Harris Director

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 624179 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States $277,643
84.173 Special Education_preschool Grants $59,124