Finding Text
2024-001 U.S. Department of Education
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster – CFDA 84.027 & 84.173
COVID-19 – Special Education Cluster – CFDA 84.027X
Material Weakness in Internal Controls Over Compliance and Compliance Finding
Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition.
Condition: Three vendors were awarded a contract without a proper competitive procurement process. A fourth vendor was awarded a contract that the School believes is a sole source procurement, but written documentation of the circumstances and rationale for the non-competitive procurement, as well as a history of the process, was not maintained by the client.
Cause: The School relied on State procurement exemptions which do not apply to Federal procurements and did not have procedures in place to document non-competitive procurements.
Effect: The School is not in compliance with Federal procurement requirements.
Questioned Costs: $466,606.60
Repeat Finding from Prior Year: No
Recommendation: The School should implement procedures to perform appropriate procurement procedures on all applicable contracts for goods and services and to maintain all required documentation of the procurement process in the School purchasing files.
Views of Responsible Official: Management agrees with the finding.