FAC Explorer

Finding 514368 (2024-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2024-12-16
Audit: 332655
Organization: Douglas County School District Re.1 (CO)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The District failed to verify the suspension and debarment status of one vendor out of eight tested, which is a significant deficiency in internal controls.
  • Impacted Requirements: Compliance with 2 CFR 200.303, which mandates effective internal controls to ensure vendors are not suspended or debarred.
  • Recommended Follow-Up: Implement policies for verifying vendor compliance for all transactions without a Master Services Agreement and review vendor status annually for long-term agreements.

Finding Text

Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: We noted that the District does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted one out of eight vendors selected for testing had not been checked to verify they were not suspended or debarred. We did verify this vendor was not currently suspended or debarred through verification per SAM.gov and therefore, the District is in compliance with the grant requirements. Questioned costs: None Context: One vendor, out of a sample of eight, was found to have no evidence of verification that the vendor was not suspended or debarred. We did later verify that the vendor was not suspended or debarred. Cause: The District switched to working with the vendor directly mid-year and did not perform the suspension and debarment check at that time. The District’s Master Service Agreements contain a clause regarding suspension and debarment but a Master Service Agreement was not entered into with the vendor at that time. Effect: The District could not be compliance with suspension and debarment requirements for its federal programs. Repeat Finding: No Recommendation: We recommend that the District implement policies for verifying suspension and debarment compliance for all transactions with vendors who do not have an existing Master Services Agreement. For vendors with long term agreements, we also recommend reviewing the vendor’s status in SAM.gov at the start of each fiscal year. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 514362 2024-001
    Significant Deficiency
  • 514363 2024-001
    Significant Deficiency
  • 514364 2024-001
    Significant Deficiency
  • 514365 2024-001
    Significant Deficiency
  • 514366 2024-001
    Significant Deficiency
  • 514367 2024-002
    Significant Deficiency
  • 514369 2024-002
    Significant Deficiency
  • 514370 2024-002
    Significant Deficiency
  • 514371 2024-002
    Significant Deficiency
  • 1090804 2024-001
    Significant Deficiency
  • 1090805 2024-001
    Significant Deficiency
  • 1090806 2024-001
    Significant Deficiency
  • 1090807 2024-001
    Significant Deficiency
  • 1090808 2024-001
    Significant Deficiency
  • 1090809 2024-002
    Significant Deficiency
  • 1090810 2024-002
    Significant Deficiency
  • 1090811 2024-002
    Significant Deficiency
  • 1090812 2024-002
    Significant Deficiency
  • 1090813 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.027 Idea Part B: Special Education (idea, Part B) $11.05M
10.555 National School Lunch Program $6.07M
10.555 Supply Assistance Grant $1.26M
10.555 Food Distribution - Commodities $1.26M
84.010 Title I, Part A $1.20M
10.553 National School Breakfast Program $759,162
84.367 Title Ii, Part A: Improving Teacher Quality $685,503
21.027 Covid-19 - Workforce Sustainability Grant $492,986
93.575 Covid-19 - Capcity Building Grant $439,946
84.425 Covid-19 - Esser III Set Aside - Learning Loss $412,804
32.009 Emergency Connectivity Fund Program $338,406
84.365 Title Iii, Part A: English Language Acquisition Grants $313,150
93.575 Emerging & Expanding Child Care Grant (eeccg) $311,713
93.575 Covid-19 - Child Care Operations Stabilization Grant $291,679
84.010 Title I, Part A - Homeless Set Aside $279,960
84.048 Career & Technical Education Grant $223,825
84.425 Covid-19 - Esser Mentor Grant $213,270
10.559 Summer Food Program for Children $193,378
84.173 Idea Part B: Special Education - Preschool $168,408
84.282 Title V, Part B: Chart School Grant $136,868
84.424 Title Iv, Part A - Well-Rounded Education $89,351
84.425 Covid-19 - Esser III Rapid Request $86,411
84.424 Title Iv, Part A - Carryover for Safe and Healthy Students $80,064
84.425 Covid-19 - Esser Elo - Summer School $79,246
10.579 Equipment Grant $70,995
84.425 Covid-19 - Esser Arp Expanded Learning Opportinity $52,508
84.424 Title Iv, Part A - Safe and Healthy Students $52,128
84.425 Covid-19 - Geer Science Bright Spot Award $50,000
84.027 Covid-19 - Arp Idea Part B: Special Education (idea, Part B) $47,281
93.575 Local Coordinating Organizations (lco) $44,990
93.575 Colorado Shines Quality Improvement (csqi) $35,222
84.425 Covid-19 - Arp-Hcy II $31,756
84.010 Title I, Part A - Parent Activities $27,456
93.354 School Nurse Workforce Grant $20,352
84.425 Covid-19 - Esser III Fund $20,062
93.575 Expanding Qaulity in Infant Toddler $16,486
84.424 Title Iv, Part A - Carryover for Well-Rounded Education $14,427
84.424 Title IV-A: Student Support and Academic Enrichment $10,059
84.010 Title I, Part A - Non-Public Set-Aside $9,161
93.575 Colorado Shines Quality Improvement (csqi) Gae $6,705
93.575 Coaches Professional Development Gae Grant $3,066
84.173 Covid-19 - Arp Idea Part B: Special Education - Preschool $2,184
66.951 Environmental Education Grants Program $1,646
84.365 Title III Immigrant Set-Aside $713
84.424 Title Iv, Part A - Effective Use of Technology $620
84.424 Title Iv, Part A - Carryover for Effective Use of Technology $95