Finding 527050 (2024-001)

CONDITION: The Leechburg Area School District contracted with TriMark for the purchase and installation of a dishwasher. This contract exceeded the Uniform Guidance micro purchase threshold of $10,000, but did not exceed the Simplified Acquisition Threshold of $250,000. The purchase was procured through a cooperative purchasing group (COSTARS). The School District was unable to provide documentation to verify that price or rate quotations were obtained from an adequate number of qualified sources. CRITERIA: Section 2 CFR 200.320(a)(2)(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a non-federal entity whereby the cost exceeds certain dollar thresholds as adjusted periodically. In instances where the cost incurred exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, price or rate quotations must be obtained from an adequate number of qualified sources. In addition, as specified in 2 CFR 200. 318(i) of the Uniform Guidance, the School District must maintain sufficient records to detail the history of procurement. CAUSE: School District personnel directly responsible for the oversight and execution of this procurement were not aware that procurement through the cooperative purchasing group (COSTARS) did not fully meet he procurement requirements as prescribed by Sections 2 CFR 200.320(a)(2)(i) and 2 CFR 200.318(i) of the Uniform Guidance. EFFECT: The Leechburg Area School District did not comply with the requirements of Sections 2 CFR 200.320(a)(2)(i) and 2 CFR 200.318(i) of the Uniform Guidance with regard to maintaining sufficient records to detail the history of procurement and conducting a cost or price analysis from an adequate number of qualified sources for a procurement in instances where the procurement cost incurred for goods and/or services exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000. QUESTIONED COST: $40,150 RECOMMENDATION: I am recommending that School District management review and update annually as necessary, School District federal financial policies and procedures to ensure In instances where the procurement cost incurred for goods and/or services exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, that 1) price or rate quotations are obtained from an adequate number of qualified sources, and 2) sufficient records are maintained to detail the history of procurement. These measures will enable the School District to comply with the procurement requirements as prescribed Sections 2 CFR 200.320(a)(2)(i) and 2 CFR 200.318(i) 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.