Finding 602549 (2022-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-30
Audit: 20587
Auditor: Bluearrow CPA

AI Summary

  • Core Issue: The School failed to check vendor suspension or debarment status on sam.gov before making payments, risking non-compliance with federal regulations.
  • Impacted Requirements: This oversight violates Uniform Grant Guidance and 2 CFR Part 200, which mandate checks on vendors to prevent funding ineligible parties.
  • Recommended Follow-up: Implement a policy requiring vendor certification of non-suspension and conduct regular checks using the GSA website before contract agreements.

Finding Text

2022-002 - Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior, U.S. Department of Education Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042, 84.027 Questioned Costs: None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 26104 2022-002
    Significant Deficiency Repeat
  • 26105 2022-003
    Significant Deficiency Repeat
  • 26106 2022-002
    Significant Deficiency Repeat
  • 26107 2022-002
    Significant Deficiency Repeat
  • 26108 2022-003
    Significant Deficiency Repeat
  • 602546 2022-002
    Significant Deficiency Repeat
  • 602547 2022-003
    Significant Deficiency Repeat
  • 602548 2022-002
    Significant Deficiency Repeat
  • 602550 2022-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
15.042 Indian School Equalization Program $3.04M
15.047 Indian Education Facilities, Operations, and Maintenance $1.54M
84.425 Education Stabilization Fund $1.38M
84.010 Title I Grants to Local Educational Agencies $879,836
15.046 Administrative Cost Grants for Indian Schools $803,361
84.027 Special Education_grants to States $350,558
15.044 Indian Schools_student Transportation $350,464
15.043 Indian Child and Family Education $142,020
15.062 Replacement and Repair of Indian Schools $135,139
10.555 National School Lunch Program $110,210
15.151 Education Program Enhancements $89,101
10.553 School Breakfast Program $61,993
84.287 Twenty-First Century Community Learning Centers $57,605
84.060 Indian Education_grants to Local Educational Agencies $33,983
84.336 Teacher Quality Partnership Grants $33,602
84.424 Student Support and Academic Enrichment Program $533