Finding Text
Procurement, Suspension and Debarment
U.S. Department of Education / Passed-through Opportunity 180
Federal Assistance Listing Number 84.282B– Charter Schools (CSP) Award Number S282A200009-20A, Subgrantee Number CSP-2021-08655, Award Date 4/1/21-8/31/23
Criteria – Management is responsible for internal controls over compliance with Procurement, Suspension and Debarment in accordance with the Uniform Guidance.
Condition – The School has policies and procedures which make reference and are in accordance with state regulation and state law, but have not been updated with sufficient clarity and detail to ensure compliance with federal law in accordance with the Uniform Guidance. Four vendors tested did not have evidence of review and approval of the bids/quotes obtained. One vendor tested did not have evidence of review and approval of the process of verifying suspension and debarment procedures.
Questioned Costs – None
Context/Sampling – A non-statistical sample of four vendors was selected for testing.
Cause – The School did not have adequate internal controls over compliance with Procurement, Suspension and Debarment in accordance with the Uniform Guidance.
Effect or potential effect – The School may follow its documented procurement policies and not identify non-compliance with federal procurement law in cases where federal procurement law is more restrictive. The School could select a vendor without proper approval. The School could enter into a transaction with a suspended or debarred vendor.
Recommendation – We recommend the School review its procurement policy and include federal procurement requirements with proper minimum and maximum thresholds and requirements of the type of bids/quotes and documentation required to meet federal compliance requirements. We recommend that the School document review and approval of all approvals and quotes/bids to ensure compliance with the Uniform Guidance. We recommend that the School maintain documentation that vendors have been verified to not be suspended or debarred before entering into a transaction with a vendor.
Views of responsible officials and planned corrective actions – Going forward, as part of the process of verifying suspension and debarment a screenshot will be saved as evidence of the process. Additionally, Academica Nevada, the School’s management company, is in the process of reviewing all existing policies and procedures to ensure clarity and compliance with federal and state standards.