Finding 584723 (2023-001)

ALN 84.027 and 84.173 Special Education Cluster (IDEA)Criteria: In accordance with 2 CFR 180.30, the School System is required to perform procedures to ensure that contractors are neither suspended nor debarred prior to entering into a contract to procure goods and services. This may be accomplished by checking the System for Award Management Exclusions, collecting a certification from the entity, or adding a clause or condition to the contract with the entity. Condition: For 2 out of 3 service contracts tested, we noted that the School System entered into a contract without performing procedures to ensure that the entity was not suspended or debarred when service contracts are contracted outside the competitive bidding process. Cause: The School System does not have adequate procedures in place to ensure controls over Federal Procurement and Suspension and Debarment compliance requirements are operating effectively. Effect: Adequate internal controls are not in place over Federal Procurement and Suspension and Debarment compliance requirements.Questioned Costs: None. Recommendation: Procedures should be implemented to ensure that contractors are neither suspended nor debarred prior to entering into a contract. School System’s Response: The School System currently has a system in place to ensure contractors are not suspended or debarred for all purchases made through the competitive bidding process. Although not required to solicit bids for service contracts, the School System chooses to do so whenever possible. The contracts tested involve service contracts that were not run though the competitive bidding process to fulfill a need beyond what could be met by then-awarded providers. The School System will update its procurement procedures to ensure that a service provider is neither suspended nor debarred prior to entering into any contract that is not subject to the competitive bidding process. The School System will ensure that all required components are included within the contract. The Supervisor of Purchasing, or his designee, will use the System for Award Management Exclusions to verify that the provider is not suspended, debarred or otherwise excluded from doing business with the government and will require an affirmation from the provider regarding non-suspension or debarment. The School System will have this in place before the June 30, 2024 audit.