2022-002: DOCUMENTATION OF PROCUREMENT, SUSPENSION, AND DEBARMENT PROCEDURES (CODE 50000) Programs Affected ESEA: Title I School Improvement Grant, U.S. Department of Education, Federal Assistance Listing Number 84.377, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER II), U.S. Department of Education, Federal Assistance Listing Number 84.425D, passed through California Department of Education, award year 2021/22, award number not available. Elementary and Secondary Emergency Relief (ESSER III) 80%, U.S. Department of Education, Federal Assistance Listing Number 84.425U, passed through California Department of Education, award year 2021/22, award number not available. Governor's Emergency Education Relief (GEER), U.S. Department of Education, Federal Assistance Listing Number 84.425C, passed through California Department of Education, award year 2021/22, award number not available. National School Lunch Program, U.S. Department of Agriculture, Federal Assistance Listing Number 10.555, passed through the California Department of Education, award year 2021/22, award number not available. ESEA: Title I, U.S. Department of Education, Federal Assistance Listing Number 84.010, passed through California Department of Education, award year 2021/22, award number not available. ESEA: Title IV, Part A, Student Support and Academic Enrichment, U.S. Department of Education, Federal Assistance Listing Number 84.424, passed through California Department of Education, award year 2021/22, award number not available. Criteria Title 2, Section 200.318 (2 CFR 200.318) of the Code of Federal Regulations (CFR), requires written policies and procedures regarding procurement of goods and services for federal awards. 2 CFR 200.320 requires that one of three procurement methods be used: Procurements by micro-purchases for acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (currently $10,000); Procurements by small purchase procedures, for securing goods or services that do not cost more than the Simplified Acquisition Threshold (currently $250,000); or Procurement by sealed bids, for goods and services in excess of the Simplified Acquisition Threshold. In addition, 2 CFR 200.213 requires that written procedures be in place for checking suspension and debarment status of certain vendors receiving federal funds from the District. Condition During our testing of expenditures, in which we tested 37 percent of all federal expenditures for goods and services, we noted that the District did not document procurement procedures and vendor suspension/debarment review for purchases charged to federal programs. Based on discussions with District management, they did perform procurement procedures regarding review of vendors for reasonable and best available pricing and for suspension and debarment, but these procedures were not documented in writing. None of the District's expenditures exceeded the Simplified Acquisition Threshold. No unallowable costs were noted as a result of this finding, and based on our review of vendors used for federal program expenditures, none of the vendors receiving federal funds were suspended or debarred in 2021/22. Identification of Repeat Finding This finding is a repeat of prior year Finding 2021-002. Cause The District did establish a form to document in writing the procurement and suspension and debarment procedures performed for vendors during the year, but did not implement the use of that form in 2021/22. Effect Based on review of detail of federal expenditures, there were no vendors or contractors who exceeded the Simplified Acquisition Threshold, and based on audit testing of significant vendors used by the District during the year, no vendors or contractors were noted who were suspended or debarred, and no unallowed expenditures were noted. Questioned Costs There are no questioned costs. However, the District did not document that it utilized the lowest cost vendor possible. The District has limited options available for vendors charged to its federal programs and it is unlikely that a reliable lower cost vendor would be found. Recommendation We recommend that the District implement the use of the form they have created to document review of multiple vendor quotes for services and for verifying that vendors are not suspended or debarred from receiving federal funds. We further recommend that the District update its procurement policy to include all federal programs. Views of Responsible Officials and Planned Corrective Actions The District agrees and will adhere to the corrective action plan described in the "District's Corrective Action Plan" section immediately following this section of the audit report.