Finding Text
2022-012: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non-federal entity must use its own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: The School has policies and procedures which make reference to state regulation and law, but the policies have not been updated with sufficient clarity and detail to ensure compliance with federal law and standards. Cause: The School did not have adequate internal controls to review its policy and procedures to include federal procurement requirements. Effect: The School may follow its documented procurement policies and not identify non-compliance with federal procurement law in cases where federal procurement law is more restrictive. Questioned Costs: None noted Context/Sampling: The School?s procurement procedures were examined in their entirety. Repeat Finding from Prior Year: No Recommendation: We recommend the School review its procurement policy and include federal procurement requirements. Views of Responsible Officials: Management agrees with this finding.