Finding 538031 (2024-002)

Criteria: In accordance with 2 CFR 180.995 when a non-Federal entity enters a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The audit identified one transaction associated with the transfer of expenditures to the Federal grant for which the Suspension and Debarment Procedures were not followed. Effect: The District is not in compliance with 2 CFR 180.995. Cause: The district made a journal entry from a local resource to a restricted federal resource without following the proper Debarment Verification Policy with Procurement Department. Repeat Finding: No Questioned Costs and Units: $50,000 Recommendation: When transactions are transferred from other resources into a federal resource, management should perform a Sam.gov check for Suspension and Debarment before the transfer occurs. Corrective Action Plan: The district will make sure to confirm with Procurement department that the vendor is not debarred from Sam.gov website before transferring any expenditure from a local resource to a restricted federal resource.