Suspension and debarment for purchase with 84.027 Special Education (IDEA) Cluster funds.
a. Type of deficiency: Significant Deficiency
i. Condition: The District did not verify that an entity was not suspended or debarred or otherwise excluded from participating in a covered transaction. A significant deficiency in controls over compliance with procurement requirements was identified.
ii. Cause: The District utilized a purchase order rather than a contract for a transaction in excess of $25,000.
iii. Effect or potential effect: Prior to entering into a covered transaction, the District did not verify that an entity was not suspended or debarred or otherwise excluded from participating in the transaction.
iv. Questioned costs: Questioned costs, if any, are indeterminable
v. Context: Of a population of 2 transactions, 1 transaction did not have documentation that the District verified that the vendor was not suspended or debarred or otherwise excluded from participating in a covered transaction.
vi. Recommendation: The District should ensure that controls are implemented to ensure that the District completes a verification that an entity is not suspended or debarred or otherwise excluded prior to entering into a covered transaction
b. Plan of acti on: The District changed its financial system to automatically notify staff that a suspension and debarment check is needed for all POs and contracts that are $25,000 and over, regardless of funding.
c. Date of implementation: December 27, 2024