Finding 523600 (2024-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
$1
Year
2024
Accepted
2025-02-19
Audit: 342986
Organization: Blackhawk School District (PA)

AI Summary

  • Core Issue: The District failed to document its rationale for a $20,000 purchase from Western PA Psych Care, which is a repeat compliance issue.
  • Impacted Requirements: This finding violates Section 2 CFR 200.318(i) and Section 2 CFR 200.320(c) of the Uniform Guidance, as well as District Procurement Policy #626.
  • Recommended Follow-Up: Ensure all future noncompetitive procurements comply with the District’s Procurement Policy and relevant federal guidelines.

Finding Text

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Western PA Psych Care’ totaling $20,000. This is a repeat finding from the previous fiscal year 2023-003 CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance, and District Procurement Policy #626, regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: $20,000 CAUSE: The District has had a long-standing relationship with Western PA Psych Care and feels that this vendor best fits the needs of the District. However, the additional procedures addressed in its Procurement Policy for Federal Programs (#626) which addresses the issue of noncompetitive procurement as outlined in Section 2 CFR 200.320(c’), were inadvertently not performed. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

Corrective Action Plan

MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The District’s timeframe for implementation is effective immediately. The District has a formal procurement policy for federal programs (#626) in place. The District hired a Business Manager effective with the 2024-2025 fiscal year who, in conjunction with the District’s Federal Program Coordinator, will be responsible for following the District’s existing procurement policy for federal programs, in particular related to this finding, the implementation of noncompetitive procurement procedures to ensure that they are followed appropriately. District Officials responsible for the implementation of the Corrective Action Plan: Dr. Johannah Vanatta, Superintendent and Erin Bluedorn, Business Manager.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1100042 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education Grants to States $366,447
84.010 Title I Grants to Local Educational Agencies $289,661
10.553 School Breakfast Program $182,586
10.555 National School Lunch Program $104,958
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $54,947
84.425 Education Stabilization Fund $22,816
84.424 Student Support and Academic Enrichment Program $21,024
93.778 Medical Assistance Program $16,888
84.173 Special Education Preschool Grants $6,624
10.649 Pandemic Ebt Administrative Costs $653