Finding Text
Program: AL 84.282A – Charter Schools Program
Criteria
In accordance with 2 CFR 200.214, non-federal entities are subject to the procurement, debarment and suspension
regulations implementing executive orders and 2 CFR part 180. These regulations restrict non-federal entities from
entering into covered transactions with certain parties that are deemed debarred, suspended or otherwise excluded
from or ineligible for participation in federal assistance programs or activities.
Condition and Context
Our World Neighborhood Charter Schools’ internal controls over compliance did not cause the entity to retain
documentation supporting compliance with the suspension and debarment regulations. In accordance with 2 CFR
200 Appendix XI, Part 3-I-2, when an entity enters into a covered transaction, a non-federal entity must verify that
the entity, as defined in 2 CFR Section 180.995, is not suspended, debarred or otherwise excluded from
participating in the transaction. Our World Neighborhood Charter Schools has a written policy that states prior to
entering into the procurement process, each vendor will be researched to determine that they have not been
suspended or debarred. However, Our World Neighborhood Charter Schools did not retain supporting
documentation to verify this research was performed.
Effect
Without appropriate documentation, non-compliance could occur which the entity may not identify.
Cause
Our World Neighborhood Charter Schools’ procurement policies did not include a requirement to retain supporting
documentation of the research performed to determine if a vendor is suspended, debarred, or otherwise excluded
from participating in the transaction.
Recommendation
We recommend the Charter Schools develop a control, with formal written documentation, showing the Charter
Schools have researched the entity prior to the Charter Schools entering into the covered transaction. This
documentation should be reviewed by the proper member of leadership to ensure the entity has been researched
prior to entering into the covered transaction. Questioned Costs: N/A
Views of Responsible Officials:
We are in agreement with the finding and Our World Neighborhood Charter Schools’ management will retain
proper support of research performed prior to entering into a covered transaction.
Auditor’s Evaluation of the Views of Responsible Officials:
Management’s response is appropriate to address the finding. If properly implemented, management’s response
would include procedures to prevent reoccurrence in the future.