Finding 627758 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-12-19

AI Summary

  • Core Issue: The District lacks a process to verify vendor compliance with suspension and debarment rules for federal programs.
  • Impacted Requirements: Federal guidelines prohibit contracting with suspended or debarred entities, especially for transactions over $25,000.
  • Recommended Follow-Up: Require bidders to submit certification of suspension and debarment with proposals and maintain this documentation for all relevant vendors.

Finding Text

Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,?is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34)Condition: The District issues a request for proposal each year to select vendors for the next school year. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $48,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $260,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 51310 2022-001
    Significant Deficiency
  • 51311 2022-001
    Significant Deficiency
  • 51312 2022-001
    Significant Deficiency
  • 51313 2022-001
    Significant Deficiency
  • 51314 2022-001
    Significant Deficiency
  • 51315 2022-001
    Significant Deficiency
  • 51316 2022-001
    Significant Deficiency
  • 627752 2022-001
    Significant Deficiency
  • 627753 2022-001
    Significant Deficiency
  • 627754 2022-001
    Significant Deficiency
  • 627755 2022-001
    Significant Deficiency
  • 627756 2022-001
    Significant Deficiency
  • 627757 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425 Covid-19 Elementary and Secondary School Emergency Relief (esser Ii) Fund $465,713
84.027 Special Education_grants to States $240,879
10.555 National School Lunch Program $77,318
84.367 Supporting Effective Instruction State Grant $29,491
10.555 Commodities- Dod (noncash) $26,415
10.555 Commodities (noncash) $24,670
10.560 Covid-19 Arp State Administrative Expenses for Child Nutrition $22,994
84.010 Title I Grants to Local Educational Agencies $9,413
10.553 School Breakfast Program $8,148
84.173 Special Education_preschool Grants $7,700
93.778 Medical Assistance Program $2,705
84.424 Student Support and Academic Enrichment Program $1,495
10.649 Covid-19 Arp Pandemic Ebt Administrative Costs $614
10.555 Covid-19 National School Lunch Program $460