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 participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s 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 $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request 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. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.