Finding Text
2022-002 ? MATERIAL WEAKNESS ? FEDERAL COMPLIANCE (50000) Federal Programs: COVID-19 - Elementary and Secondary School Emergency Relief Fund (AL#84.425), COVID-19 - Elementary and Secondary School Relief II Fund (AL#84.425) ? collectively referred to herein as ?COVID-19 -ESF Programs?. Criteria: Per the Uniform Guidance Compliance Supplement, established in accordance with 2 CFR Part 200, Subpart F: Sections A. Activities Allowed or Unallowed, and F. Equipment/Real Property Management require that recipients of Federal funds follow applicable specific requirements in connection with the expenditure of the grant fund Condition: The District entered into an agreement with a third-party vendor for products and services but did not follow applicable written internal control procedures over bidding and board approval or obtain prior approval from the California Department of Education, as required for equipment and real property purchases by the COVID-19 ? ESF Programs. The Uniform Guidance compliance also require internal control procedures to be in place and followed in order to demonstrate compliance with the requirements. As a result, the District did not have appropriate internal control procedures in place, nor was the agreement compliant with Uniform Guidance requirements. Effect: The District did not comply with the necessary requirements for entering into the agreement for the purchase of equipment and real property, therefore resulting in risk of loss of funding for amounts paid under the third-party vendor agreement. Cause: The District did not follow necessary internal controls for ensuring compliance with the specific program requirements of the Education Stabilization Fund grants it received and expended during the year ended June 30, 2022. Questioned Cost: $6,604,857 Recommendation: The District?s management team should implement necessary internal controls to ensure compliance with all Federal program requirements. The internal controls should include (1) a procedure identifying which attributes apply to each Federal program operated by the District, and (2) steps to ensure compliance with each attribute identified as applicable. Views of Responsible Officials and Planned Corrective Action: Management concurs with findings. District management will continue to provide staff members internal control procedure training specifically in the areas of federal procurement. This will ensure adherence to Federal program requirements. Management staff received procurement training in October 2022. Subsequently, in February and March 2023, management provided procurement trainings to sites and departments.