Finding 4882 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2023-12-17

AI Summary

  • Core Issue: The School District failed to verify that contractors and vendors receiving over $25,000 were not suspended or debarred before engaging in business.
  • Impacted Requirements: This violates Section 200.214 of the Uniform Guidance, which mandates verification to prevent fraud and ensure compliance with federal assistance programs.
  • Recommended Follow-up: The School District should adhere to its verification procedures and maintain documentation of checks performed on vendor eligibility.

Finding Text

Finding 2023-001: Special Education Cluster Suspension and Debarment Procedures U.S. Department of Education Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 84.027A, 84.027X, 84.173A and 84.173X Award numbers: 220450 21-22, 230493 22-23, 230450 22-23, COVID-19 221280 21-22, 220460 21-22, 230460 22-23 and COVID-19 221285 21-22 Award year ends: June 30, 2023, September 30, 2023 and September 30, 2024 Specific Requirement: Suspension and Debarment Criteria: Section 200.214 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. This guidance requires a non-federal entity to establish policies and procedures for verifying the status of contractors and vendors whenever the value of a contract or cumulative transactions is expected to equal or exceed $25,000 to protect the federal government from fraud, waste and abuse. Questioned Costs: None. Condition: During our detailed testing of suspension and debarment for the Special Education Cluster, we noted that the School District did not verify that its contractors and vendors receiving payments in excess of $25,000 were not suspended or debarred prior to doing business with them. Context: One vendor charged to the Special Education Cluster received payments in excess of the $25,000 testing threshold during the fiscal year, but the School District did not perform the necessary suspension or debarment testing prior to doing business with them. A subsequent vendor search on the federal System for Award Management (SAM.gov) website indicated that the vendor was not ineligible for participation in federal assistance programs or activities. The sample was not a statistically valid sample. Effect: Failure to verify the status of contractors and vendors prior to entering into business contracts or transactions that equal or exceed $25,000 could result in business activities with ineligible vendors and disallowed federal program expenditures. Cause: The School District did not follow its established procedure for verifying that its contractors and vendors were not suspended or debarred prior to entering into business contracts or transactions that equaled or exceeded $25,000 for any of its grant-funded programs. Repeat Finding: This is not a repeat finding. Recommendation: The School District should follow its suspension and debarment procedures for verifying the eligibility of its contractors and vendors prior to entering into business contracts or transactions that equal or exceed $25,000 in value. In addition, the School District should retain supporting documentation of these verifications performed, such as the printing of vendor search results from the SAM.gov website. Views of Responsible Officials: The School District agrees with this finding.

Corrective Action Plan

Finding 2023-001: Special Education Cluster Suspension and Debarment Procedures Recommendation: The School District should follow its suspension and debarment procedures for verifying the eligibility of its contractors and vendors prior to entering into business contracts or transactions that equal or exceed $25,000 in value. In addition, the School District should retain supporting documentation of these verifications performed, such as the printing of vendor search results from the SAM.gov website. Action Taken: At the start of each fiscal year, the School District will generate a list of vendors that were paid amounts in excess of $25,000 in the previous fiscal year. Vendor searches will be completed and documented on all these vendors using the SAM.gov website. All purchase requisitions made exceeding $10,000 will reference the MAISD Debarment list to ensure the suspension and debarment procedures were completed. Vendor searches will be performed and added to the MAISD Debarment list if vendor is not already on list. Requisitions will be denied if vendor is ineligible for participation in federal assistance programs or activities. Responsible Person and Anticipated Completion Date: Director of Financial Services, October 2023. If the Michigan Department of Education has questions regarding this plan, please call Jesse Rickard at (231) 767-7209.

Categories

Procurement, Suspension & Debarment Eligibility

Other Findings in this Audit

  • 4883 2023-002
    Significant Deficiency
  • 4884 2023-001
    Significant Deficiency
  • 4885 2023-002
    Significant Deficiency
  • 4886 2023-001
    Significant Deficiency
  • 4887 2023-002
    Significant Deficiency
  • 4888 2023-001
    Significant Deficiency
  • 4889 2023-002
    Significant Deficiency
  • 581324 2023-001
    Significant Deficiency
  • 581325 2023-002
    Significant Deficiency
  • 581326 2023-001
    Significant Deficiency
  • 581327 2023-002
    Significant Deficiency
  • 581328 2023-001
    Significant Deficiency
  • 581329 2023-002
    Significant Deficiency
  • 581330 2023-001
    Significant Deficiency
  • 581331 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.600 Head Start $9.15M
84.027 Special Education_grants to States $1.24M
84.184 Safe and Drug-Free Schools and Communities_national Programs $744,614
84.010 Title I Grants to Local Educational Agencies $594,623
84.048 Career and Technical Education -- Basic Grants to States $429,680
21.027 Coronavirus State and Local Fiscal Recovery Funds $312,082
93.778 Medical Assistance Program $126,777
84.173 Special Education_preschool Grants $115,013
11.429 Marine Sanctuary Program $79,975
84.425 Education Stabilization Fund $57,087
84.196 Education for Homeless Children and Youth $33,477
10.553 School Breakfast Program $29,524
93.575 Child Care and Development Block Grant $25,000
84.365 English Language Acquisition State Grants $22,911
93.434 Every Student Succeeds Act/preschool Development Grants $17,785
10.555 National School Lunch Program $9,300
84.181 Special Education-Grants for Infants and Families $4,786
10.559 Summer Food Service Program for Children $3,743
10.649 Pandemic Ebt Administrative Costs $3,135
84.013 Title I State Agency Program for Neglected and Delinquent Children and Youth $0