Finding 59147 (2022-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-11-08

AI Summary

  • Core Issue: The School District did not follow competitive bidding procedures for contractor selection.
  • Impacted Requirements: Violations of 48 CFR Section 52.244-5(a) and 2 CFR Section 200.318(i) regarding procurement documentation.
  • Recommended Follow-Up: Ensure adherence to state and federal procurement guidelines for future contracts and maintain proper documentation.

Finding Text

2022-002: Procurement and Suspension and Debarment Federal Agency: U.S. Department of Education Special Education Cluster (IDEA); Federal Assistance Listing Number 84.027, Special Education ? Grants to States; Federal Assistance Listing Number 84.173, Special Education ? Preschool Grants Criteria: 48 CFR Section 52.244-5(a) states, ?The Contractor shall select subcontractors (including suppliers) on a competitive basis to the maximum practical extent consistent with the objectives and requirements of the contract.? Further, 2 CFR Section 200.318(i) states, ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? Condition: Both of the samples we selected for testing did not follow competitive bidding procedures or maintain documents as to the rationale for the method of procurement and contractor selection or rejection. Cause: The School District only renewed the contracts and did not provide for an opportunity for competitive bidding procedures. Effect or Potential Effect: The School District could be paying more than a reasonable amount for the services provided. Recommendation: The School District should follow state and federal procurement guidelines and select contractors on a competitive basis. The School District went through proper bidding procedures for 2022-23 fiscal year for procurement of services. Management?s Response: See corrective action plan.

Corrective Action Plan

Segregation of Duties Recommendation: In regards to the payroll function, we noted that although the payroll clerk does not have access to certain rights or functions within the payroll system such as the ability to modify employees? salaries, the individual is performing all payroll duties. In regards to claims/cash disbursements, while the system allows the accounts payable clerk to add and modify vendors, the School District does have a process in place of adding new vendors which requires the signature of an Administrator; however, overall, we suggest that the segregation of duties be reviewed and adjusted where possible to strengthen the system of internal control. It should be noted that the School District has hired a Treasurer after fiscal year end, and payroll claims functions should be segregated to strengthen the system of internal control. Management?s Response: The District agrees regarding the need for segregation of duties. We now have a separate, full-time Treasurer who does not serve as the Payroll Clerk. Additionally, the Assistant Superintendent of Business reviews payroll and all supporting documentation during the certification of payroll. Finally, with the reorganization of work that has occurred in the business office, the creation and modification of vendors within the financial management system will be reassigned. In this way, the accounts payable clerk will no longer have access to activate new vendors or to modify existing vendors. Procurement and Suspension and Debarment Recommendation: The sample we selected for testing did not follow competitive bidding procedures or maintain documents as to the rationale for the method of procurement and contractor selection or rejection. However, management took remedial action in 2022-2023 as we noted an RFP. 48 CFR Section 52.244-5(a) states, ?The Contractor shall select subcontractors (including suppliers) on a competitive basis to the maximum practical extent consistent with the objectives and requirements of the contract.? Further, 2 CFR Section 200.318(i) states, ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but not necessarily limited to, the following: Rational for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? The School District has taken remedial action for fiscal 2022-2023 and should continue to follow State and Federal procurement guidelines and select contractors on a competitive basis. Management?s Response: The District issued a Request for Proposals (RFP) to ensure that procurement of said professional services is consistent with Federal and State requirements. The District intends to maintain this system of procurement in the future. Internal Balances (Due To/From Accounts) Recommendation: The School District should clear all interfund balances to the extent possible in accordance with General Municipal law. Management?s Response: As previous noted by the immediate past Assistant Superintendent for Business, the interfund balances are maintained by a part-time Treasurer/Payroll Clerk and the Accounting Consultants, Management Advisory Group. Now that a full-time Treasurer has been hired, the review and clearing of these interfund balances will now be completed on a regular schedule, and in all cases, these internal balances will be cleared by June each year. Extraclassroom Activity Funds Recommendation: (Regarding Clubs with no activity) State Education Regulations provide that inactive funds shall remain in the custody of the Central Treasurer for six months and then either expended by vote of the organization controlling the funds as provided for in the bylaws or transferred to the general student organization or student council. A determination of the status of the clubs with no financial activity should be made to determine the proper disposition of funds. This will deter all clubs from becoming inactive in future years. The School District does have a policy in place to transfer inactive funds to the student organization. Management?s Response: Twenty clubs is a lot of clubs to be inactive. Some of the Clubs? inactivity is due to remnant COVID issues. The District will work with advisors to re-initiate activity, and for those clubs that we know will be inactive, we will transfer funds to the Student Council organization and notify the clubs, as appropriate. Special Purpose Fund Recommendation: We recommend that Trust agreements be located and filed accordingly so as to determine that revenues and related expenditures are within the terms of the agreements. Management?s Response: Moving forward, the District will maintain the scope and criteria of newly created scholarships. This new file will include the requirements for selection of scholarship awardees. Recommendation: We suggest that the School District analyze the balances and review the purposes of these funds so that a determination may be made as to the proper disposition of funds. Should it be determined that these amounts are no longer required to be held in trust, a board resolution should be approved transferring these funds to the General fund. We suggest that as previously mentioned, a schedule of each individual trust be prepared, and interest earned should be allocated accordingly, rather than having an account entitled Interest Earnings. Management?s Response: All scholarships will be moved to a separate bank account, instead of being co-mingled with other activities within the Special Revenue Account. This will enable us to track earned interest more granularly and allocate that interest accordingly.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 59148 2022-002
    Significant Deficiency Repeat
  • 59149 2022-002
    Significant Deficiency Repeat
  • 59150 2022-002
    Significant Deficiency Repeat
  • 635589 2022-002
    Significant Deficiency Repeat
  • 635590 2022-002
    Significant Deficiency Repeat
  • 635591 2022-002
    Significant Deficiency Repeat
  • 635592 2022-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program -Cash $1.03M
84.425 Elementary and Secondary School Emergency Relief (esser Ii) Fund (crrsa) $823,165
84.010 Title I Grants to Local Educational Agencies $440,801
10.553 School Breakfast Program $381,768
84.425 Elementary and Secondary School Emergency Relief (esser) Fund (cares) $339,159
97.036 Division of Homeland Security and Emergency Services $197,341
84.425 Governor's Emergency Education Relief (geer Ii) Fund (crrsa) $163,445
84.425 American Rescue Plan Elementary and Secondary School Emergency Relief (arp Esser) Fund $82,550
84.425 Governor's Emergency Education Relief (geer) Fund (cares) $56,557
10.555 National School Lunch Program - Commodities $50,910
10.559 Summer Food Service Program for Children $45,205
84.367 Supporting Effective Instruction State Grants $38,956
84.027 Special Education_grants to States $36,016
84.424 Student Support and Academic Enrichment Program $26,633
84.365 English Language Acquisition State Grants $26,545
84.173 Special Education_preschool Grants $7,802
10.649 State Pandemic Ebt Administrative Costs Grants $2,404