Finding 660722 (2022-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-28

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls for procurement and vendor verification, leading to noncompliance with federal and state regulations.
  • Impacted Requirements: Failure to follow procurement procedures, including obtaining necessary price quotes and verifying vendor eligibility, violates 2 CFR 200.303 and Indiana Code 5-22-8.
  • Recommended Follow-Up: Implement robust internal controls for procurement processes and ensure compliance with all federal and state requirements to prevent future findings.

Finding Text

FINDING 2022-004 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 27 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-012. Condition and Context An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not have internal controls in place to ensure the purchasing method used complied with federal and state requirements. The School Corporation did not obtain price or rate quotes for two vendors tested that were less than the simplified acquisition threshold of $150,000, but exceeded the $10,000 micro-purchase threshold. The micropurchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. The School Corporation did not obtain a contract for these two vendors as required by Indiana Code for purchases between $50,000 and $150,000. Additionally, documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit for both purchases made using the small purchases and micro-purchases procurement methods. Suspension and Debarment There were no internal controls in place to ensure that vendors were not suspended or debarred from participation in federal programs. The School Corporation did not perform any procedures to verify that vendors paid with federal grant monies were not suspended or debarred from participation in federal programs before entering into a covered transaction. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 28 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 (Uniform Guidance) states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the Simplified Acquisition Threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." INDIANA STATE BOARD OF ACCOUNTS 29 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 84273 2022-003
    Material Weakness
  • 84274 2022-004
    Material Weakness Repeat
  • 84275 2022-003
    Material Weakness
  • 84276 2022-004
    Material Weakness Repeat
  • 84277 2022-003
    Material Weakness
  • 84278 2022-004
    Material Weakness Repeat
  • 84279 2022-003
    Material Weakness
  • 84280 2022-004
    Material Weakness Repeat
  • 84281 2022-003
    Material Weakness
  • 84282 2022-004
    Material Weakness Repeat
  • 84283 2022-003
    Material Weakness
  • 84284 2022-004
    Material Weakness Repeat
  • 84285 2022-003
    Material Weakness
  • 84286 2022-004
    Material Weakness Repeat
  • 84287 2022-003
    Material Weakness
  • 84288 2022-004
    Material Weakness Repeat
  • 84289 2022-003
    Material Weakness
  • 84290 2022-004
    Material Weakness Repeat
  • 84291 2022-010
    Material Weakness
  • 84292 2022-011
    Material Weakness
  • 84293 2022-012
    Material Weakness Repeat
  • 84294 2022-010
    Material Weakness
  • 84708 2022-011
    Material Weakness
  • 84709 2022-010
    Material Weakness
  • 84710 2022-011
    Material Weakness
  • 84711 2022-012
    Material Weakness Repeat
  • 84712 2022-005
    Material Weakness
  • 84713 2022-006
    Material Weakness Repeat
  • 84714 2022-007
    Material Weakness
  • 84715 2022-008
    Material Weakness Repeat
  • 84716 2022-009
    Material Weakness Repeat
  • 84717 2022-005
    Material Weakness
  • 84718 2022-006
    Material Weakness Repeat
  • 84719 2022-007
    Material Weakness
  • 84720 2022-008
    Material Weakness Repeat
  • 84721 2022-009
    Material Weakness Repeat
  • 84722 2022-013
    Material Weakness
  • 84723 2022-014
    Material Weakness
  • 84724 2022-015
    Material Weakness
  • 84725 2022-016
    Material Weakness
  • 84726 2022-013
    Material Weakness
  • 84727 2022-014
    Material Weakness
  • 84728 2022-015
    Material Weakness
  • 84729 2022-016
    Material Weakness
  • 84730 2022-013
    Material Weakness
  • 84731 2022-014
    Material Weakness
  • 84732 2022-015
    Material Weakness
  • 84733 2022-016
    Material Weakness
  • 84734 2022-013
    Material Weakness
  • 84735 2022-014
    Material Weakness
  • 84736 2022-015
    Material Weakness
  • 84737 2022-016
    Material Weakness
  • 660715 2022-003
    Material Weakness
  • 660716 2022-004
    Material Weakness Repeat
  • 660717 2022-003
    Material Weakness
  • 660718 2022-004
    Material Weakness Repeat
  • 660719 2022-003
    Material Weakness
  • 660720 2022-004
    Material Weakness Repeat
  • 660721 2022-003
    Material Weakness
  • 660723 2022-003
    Material Weakness
  • 660724 2022-004
    Material Weakness Repeat
  • 660725 2022-003
    Material Weakness
  • 660726 2022-004
    Material Weakness Repeat
  • 660727 2022-003
    Material Weakness
  • 660728 2022-004
    Material Weakness Repeat
  • 660729 2022-003
    Material Weakness
  • 660730 2022-004
    Material Weakness Repeat
  • 660731 2022-003
    Material Weakness
  • 660732 2022-004
    Material Weakness Repeat
  • 660733 2022-010
    Material Weakness
  • 660734 2022-011
    Material Weakness
  • 660735 2022-012
    Material Weakness Repeat
  • 660736 2022-010
    Material Weakness
  • 661150 2022-011
    Material Weakness
  • 661151 2022-010
    Material Weakness
  • 661152 2022-011
    Material Weakness
  • 661153 2022-012
    Material Weakness Repeat
  • 661154 2022-005
    Material Weakness
  • 661155 2022-006
    Material Weakness Repeat
  • 661156 2022-007
    Material Weakness
  • 661157 2022-008
    Material Weakness Repeat
  • 661158 2022-009
    Material Weakness Repeat
  • 661159 2022-005
    Material Weakness
  • 661160 2022-006
    Material Weakness Repeat
  • 661161 2022-007
    Material Weakness
  • 661162 2022-008
    Material Weakness Repeat
  • 661163 2022-009
    Material Weakness Repeat
  • 661164 2022-013
    Material Weakness
  • 661165 2022-014
    Material Weakness
  • 661166 2022-015
    Material Weakness
  • 661167 2022-016
    Material Weakness
  • 661168 2022-013
    Material Weakness
  • 661169 2022-014
    Material Weakness
  • 661170 2022-015
    Material Weakness
  • 661171 2022-016
    Material Weakness
  • 661172 2022-013
    Material Weakness
  • 661173 2022-014
    Material Weakness
  • 661174 2022-015
    Material Weakness
  • 661175 2022-016
    Material Weakness
  • 661176 2022-013
    Material Weakness
  • 661177 2022-014
    Material Weakness
  • 661178 2022-015
    Material Weakness
  • 661179 2022-016
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund Fy 22 $3.37M
10.555 National School Lunch Program Fy 22 $1.35M
10.555 National School Lunch Program Fy 21 $706,165
84.027 Special Education_grants to States Fy 21 $643,609
84.010 Title I Grants to Local Educational Agencies Fy 22 $556,128
84.010 Title I Grants to Local Educational Agencies Fy 21 $525,380
84.027 Special Education_grants to States Fy 22 $472,800
10.553 School Breakfast Program Fy 22 $348,509
94.006 Americorps Fy 22 $205,555
10.553 School Breakfast Program Fy 21 $199,694
94.006 Americorps Fy 21 $151,960
93.778 Medical Assistance Program Fy 22 $119,430
10.559 Summer Food Service Program for Children Fy 22 $115,185
84.367 Improving Teacher Quality State Grants Fy 21 $93,813
93.778 Medical Assistance Program Fy 21 $87,163
84.367 Improving Teacher Quality State Grants Fy 22 $62,499
84.425 Education Stabilization Fund Fy 21 $61,881
84.358 Rural Education Fy 21 $36,737
84.173 Special Education_preschool Grants Fy 21 $35,011
84.424 Student Support and Academic Enrichment Program Fy 21 $26,273
10.579 Child Nutrition Discretionary Grants Limited Availability Fy 21 $12,466
10.579 Child Nutrition Discretionary Grants Limited Availability Fy 22 $8,690
10.649 Pandemic Ebt Administrative Costs Fy 22 $3,063
10.559 Summer Food Service Program for Children Fy 21 $1,334