Finding Text
SECTION III - FEDERAL AND STATE AWARD FINDINGS AND QUESTIONED COSTS 2022-002 SUSPENSION AND DEBARMENT Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund (ESF) ALN Numbers: 84.425 ? COVID-19: Higher Education Emergency Relief Fund ? Student Aid 84.425 ? COVID-19: Higher Education Emergency Relief Fund ? Institutional Portion Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to nonprocurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that one vendor were not suspended or debarred prior to the purchase. Questioned costs: None Context: For 1 of the 6 vendors selected for testing in a non-statistically valid sample, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their control processes related to the verification and documentation of the vendor?s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation of the internal control process over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.