Finding 601853 (2022-003)

Material Weakness
Requirement
P
Questioned Costs
-
Year
2022
Accepted
2023-03-23

AI Summary

  • Core Issue: The District lacks a consistent process to verify vendors for suspension or debarment before engaging in covered transactions.
  • Impacted Requirements: Compliance with federal regulations requiring checks against suspended or debarred vendors for transactions over $25,000.
  • Recommended Follow-up: Implement and document control procedures to verify vendor status before transactions, ensuring compliance with federal guidelines.

Finding Text

2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 section 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 for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2022, it does not appear that the expenditures under the federal grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. Any such controls are not documented for a proper audit trail. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 24326 2022-003
    Material Weakness
  • 24327 2022-003
    Material Weakness
  • 24328 2022-003
    Material Weakness
  • 24329 2022-003
    Material Weakness
  • 25202 2022-003
    Material Weakness
  • 25410 2022-004
    Material Weakness
  • 25411 2022-003
    Material Weakness
  • 600768 2022-003
    Material Weakness
  • 600769 2022-003
    Material Weakness
  • 600770 2022-003
    Material Weakness
  • 600771 2022-003
    Material Weakness
  • 601644 2022-003
    Material Weakness
  • 601852 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.553 School Breakfast Program $1.49M
32.009 Emergency Connectivity Fund Program $835,068
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $820,428
84.060 Indian Education_grants to Local Educational Agencies $456,782
10.555 National School Lunch Program $421,313
84.367 Improving Teacher Quality State Grants $274,923
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $180,562
84.027 Special Education_grants to States $169,173
84.013 Title I State Agency Program for Neglected and Delinquent Children and Youth $145,843
10.559 Summer Food Service Program for Children $143,873
84.173 Special Education_preschool Grants $135,841
84.048 Career and Technical Education -- Basic Grants to States $112,189
84.365 English Language Acquisition State Grants $101,350
84.424 Student Support and Academic Enrichment Program $86,429
84.002 Adult Education - Basic Grants to States $76,408
93.959 Block Grants for Prevention and Treatment of Substance Abuse $73,540
15.130 Indian Education_assistance to Schools $55,964
84.010 Title I Grants to Local Educational Agencies $18,047
10.649 Pandemic Ebt Administrative Costs $5,814
84.425 Education Stabilization Fund $5,404
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $4,433