Finding 578011 (2022-006)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-11-09
Audit: 2809
Organization: Na' Neelzhiin Ji Olta' Inc. (NM)
Auditor: Blue Arrow INC

AI Summary

  • Core Issue: The School failed to verify vendor eligibility, resulting in noncompliance with procurement regulations.
  • Impacted Requirements: Non-federal entities must check for vendor suspension or debarment before contracting, as outlined in 2 CFR §180.
  • Recommended Follow-up: Implement annual checks for vendor eligibility on transactions over $25,000 to ensure compliance.

Finding Text

2022-006 Procurement, Suspension, and Debarment (Significant Deficiency) - Repeated & Modified (Prior Year Finding 2021-006) Federal Program Information: Funding Agency Title ALN # Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2021 AI9AV00859 Criteria or Specific Requirement Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended, or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition During the testwork over procurement, we noted that for all three (3) transactions over $25,000 tested, the School was unable to provide documentation showing that the procurement process was followed. In addition, there was no documentation showing that the School had searched the respective vendor on the System for Award Management (sam.gov) to ensure that the vendor was not suspended or debarred. Questioned Costs The calculation of questioned costs was not determinable for these instances of noncompliance. Cause The School did not follow its policies and procedures regarding procurement, suspension, and debarment. Effect Noncompliance with grant requirements. Auditor's Recommendation For procurements over $25,000, the School should implement policies and procedures that ensure suspension and debarment checks are performed annually on required vendors.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1569 2022-006
    Significant Deficiency Repeat
  • 1570 2022-007
    Significant Deficiency Repeat
  • 1571 2022-007
    Significant Deficiency Repeat
  • 578012 2022-007
    Significant Deficiency Repeat
  • 578013 2022-007
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
15.042 Indian School Equalization Program $2.02M
15.046 Administrative Cost Grants for Indian Schools $751,130
84.010 Title I Grants to Local Educational Agencies $657,543
15.047 Indian Education Facilities, Operations, and Maintenance $614,464
15.043 Indian Child and Family Education $377,161
10.533 Snap-Ed Toolkit $155,185
84.027 Special Education_grants to States $136,684
15.044 Indian Schools_student Transportation $116,534
84.060 Indian Education_grants to Local Educational Agencies $88,919
84.425 Education Stabilization Fund $28,022