Finding Text
Assistance Listing, Federal Agency, and Program Name - 21.027 - COVID - 19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - SLFRP0126
Pass through Entity - U.S. Department of Treasury
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - 2 CFR 200.320 and 200.324 outlines the auditee responsibility to utilize the appropriate procurement method and comply with all related requirements of that selected procurement methodology. Also, 2 CFR 180.300 outlines the auditee responsibility related to suspension and debarment requirements for vendors with whom an entity contracts.
Condition - The School District did not have sufficient controls in place to ensure compliance with its procurement policy and that appropriate documentation is retained regarding the procurement methodology chosen and support for compliance with the suspension and debarment requirements.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the sample of 2 contracts procured this year that we selected for testing, 2 did not have the required support for the procurement method selected based on federal guidelines and the School District's procurement policy. Additionally, the 2 contracts selected for suspension and debarment testing did not have any documentation as it related to suspension and debarment.
Cause and Effect - The School District did not retain support to show it obtained price quotes, as required by the small purchases provision; had the appropriate rationale, as required by the noncompetitive solicitation provision; or had support for proposals submitted, as required by the purchases over $250,000 provision. Support was not retained for 2 of the 2 samples selected during procurement testing; therefore, procurement methodology was not supported. Additionally, none of the 2 samples selected for suspension and debarment testing had the required support retained.
Recommendation - We recommend the School District implement internal control procedures to ensure that procurement policy is followed and the proper documentation is kept in the procurement files to support any and all procurement decisions in accordance with the purchasing policy and federal regulations.
Views of Responsible Officials and Planned Corrective Actions - This finding was due to the District having turnover among key personnel in the grants area, as well as non adherence to policies and procedures related to grant records, grant accounting, and year end close processes. The District will work with the Materials and Procurement department to ensure policies and procedures are updated and staff is trained. Prior to awarding any contract, District staff will search the federal Excluded Parties List System to determine that the contractor is not suspended or debarred. Documentation of this search will be maintained in the grant procurement file.