Finding Text
2022-003 Procurement Documentation Federal Agency: U.S. Department of Education Federal Program Title: Special Education Cluster (IDEA) Federal ALN: 84.027, 84.173A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2022-631526-DPI-IDEA-FT-341, 2022-631526-DPI-IDEA-P-347 Award Period: July 1, 2021 - June 30, 2022 Type of Finding: Significant deficiency in internal control over compliance, Other Matters Compliance Requirement: Procurement Condition: The District entered into a contract over $10,000 and did not maintain any documentation of price comparisons if the procurement transaction was classified as a small purchase or justification if the procurement was classified as a a sole source. Criteria: Uniform Guidance requires Districts to implement a procurement policy that complies with federal regulations regarding the types of procurement and the dollar thresholds involved. Uniform Guidance also requires that Districts to implement a system of internal controls to ensure procurement transactions complies with their own policy and the uniform guidance regulations. Questioned Costs: None Context: The District entered into one procurement transaction in excess of the micropurchase threshold during the grant period. Documentation of the procurement method was not maintained. Cause: The District policy does not provide any guidance as to the procedures to follow between the micropurchase threshold of $10,000 and the $150,000 procurement threshold requiring competitive proposals. Effect: The District could utilize a method of procurement in violation of federal uniform grant guidance. Repeat Finding: Repeat of Finding 2021-003 Recommendation: We recommend that the District review its procurement policies in relation to the federal requirements and consider implementing a micro-purchase method of procurement as well as eliminating any discrepancies in dollar amounts listed in the policy. In addition, we recommend the district review its procedures and internal controls to maintain documentation to support the method of procurement Views of responsible officials: There is no disagreement with the audit finding.