Finding Text
Finding Number Compliance Deficiencies
2024-005 Special Education Cluster: Procurement, Suspension, and Debarment
Federal Agency: United States Department of Education
Federal program Name: Special Education Cluster
Assistance Listing Number: 84.024, 84.173
Federal Award Identification Number and Year: Unknown
Pass-through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2024-585264-DPI-FLOW-341, 2024-585264-DPI-PRESCH-347
Award Period: 07/01/2023 – 06/30/2024
Compliance Requirements Affected: Procurement, Suspension, and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)
Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required.
2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded.
Questioned costs: None
Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. In our sample of twelve vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for one vendor. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all three vendors that were selected for testing.
Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment.
Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued)
Finding Number Compliance Deficiencies
2024-005 Special Education Cluster: Procurement, Suspension, and Debarment (Continued)
Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Additionally, the District could contract with a vendor that has been suspended or debarred from receiving Federal funds.
Repeat Finding: No
Recommendation: We recommend that the District review its procedures to ensure that the District’s procurement policy and suspension and debarment policy are being consistently followed. We further recommend that the District require all grant administrators to receive training on Federal procurement and suspension and debarment regulations.
View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.