Finding 580852 (2023-002)

Suspension and Debarment Finding Type. Immaterial Noncompliance (Procurement, Suspension and Debarment). Program. Special Education Cluster; U.S. Department of Education; Assistance Listing Number 84.027X, Award 221280-2122. Criteria. Recipients of federal awards are required to follow their own internal purchasing policies, as well as complying with purchasing standards set forth in the Uniform Guidance. Part of that guidance requires an entity to check if a vendor is suspended or debarred before entering into a contract. Condition. The District was unable to provide documentation to support its consideration of suspension and debarment requirements for the vendor selected for testing. Cause. The District does not have the proper internal controls in place to ensure that documentation of the verification is retained in accordance with federal requirements. Effect. The District is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the District's internal controls. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs, and the vendor in question was not actually suspended or debarred. Recommendation. We recommend that the District implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained. View of Responsible Officials. The District will implement the necessary internal controls to ensure the policy for compliance is followed and documented.