Finding Text
Procurement, Suspension and Debarment (Repeat Finding 2022-012)
U.S. Department of Education/Passed-through Opportunity 180
Federal Assistance Listing Number 84.282B – Charter Schools
Award Number S282A200009-20A, Subgrantee Number CSP-2021-56278,
Award Date April 1, 2021–August 31, 2023
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 that make reference to state
regulation and law, but the policies have not been updated with sufficient clarity and
detail to ensure compliance with federal law and standards. Nine vendors tested did
not have evidence of review and approval of the bids/quotes obtained. Eight vendors
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 10 vendors was selected for testing.
Cause – The School did not have adequate internal controls to review its policy and
procedures to include federal procurement requirements.
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 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 the School document review
and approval of all approvals and quotes/bids to ensure compliance with the Uniform
Guidance. We recommend 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.