Finding 510791 (2024-003)

Written Procurement Policy This finding impacts the procurement and suspension and debarment compliance requirement for the major program, Assistance Listing Number 84.282, Charter Schools, funded by U.S. Department of Education, passed through the Commonwealth of Massachusetts, Department of Elementary and Secondary Education (DESE). Criteria: The School must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. The School also 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. Condition: During our compliance testing, we reviewed the School's procurement policy against Uniform Guidance standards. The policy did not meet all of the considerations that are required through Federal, Uniform Guidance, and state regulations. The School followed their procurement policy during fiscal year 2024, but should update this policy in accordance with these regulations Context: Compliance with the Uniform Guidance. Cause: The School’s existing procurement policy was not updated to include all of the elements required by the Uniform Guidance. Effect: Non-compliance with the Uniform Guidance, potentially resulting in a decrease in Federal funding and allow for purchases that are not completed under the approved procurement standards. Questioned Costs: No questioned costs identified. Was the finding a repeat of a finding in the immediately prior year?: No Recommendation: AAFCPAs recommends that management revise their policy to comply with current standards under the Uniform Guidance. Management’s Response: The current School policy was adopted at opening based on DESE recommended Fiscal Policy and Procedures. Given the analysis of the current policy as compared to the Uniform Guidance policy, the School policy will be updated to ensure compliance going forward. This policy will be reviewed by the Finance Committee and then brought to the full Board for approval no later than January 2025.