Finding Text
Finding Criteria ? A component of compliance relating to federal awards is maintaining records sufficient to detail the history of procurement. These records will include, but are 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 Found ? The District used federal ESSER funds to make purchases greater than $10,000 to $21,900 without obtaining at least three quotes, made purchases greater than $21,900 and did not obtain at least three public bids. Cause of the Finding ? The District was under the false notion that purchases made through the Commonwealth of Pennsylvania?s cooperative purchasing program COSTARS satisfied compliance requirement of quote/bid requirements for federal purchases. Effect of the Finding ? The District was not in compliance with procurement requirements for federal funds. Questioned Costs ? Purchases made under the false notion that COSTARS satisfied three-quote requirement total $23,077 (3% of ESSERS expense), and satisfied three-bid requirement total $247,987 (27% of ESSERS expense). Recommendations - Documentation is key for all federal purchases. A purchase price from cooperative purchasing programs can be considered one competitive price proposal and cannot replace a procurement process. Advertise when appropriate, obtain adequate quote/bid information from three vendors, and thoroughly document the ?reason? and ?cost analysis? of sole source noncompetitive procurement exceptions. Management's Response - The District will follow the policy for quotation/bid requirements for federal purchases and not use cooperative purchasing programs as the only source of quotations/bids for federal purchases. The District will also improve documentation relating to purchases that meet sole source criteria.