Finding Text
Finding Number: 2023‐002
Repeat Finding: Yes, 2022‐002
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization Program 15.042 A22AV00793 N/A
Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A
Federal Agency: U.S. Department of Interior
Pass‐Through Agency: Bureau of Indian Education
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirements: Procurement and Suspension and Debarment
Criteria
Non‐federal entities are prohibited from contracting with or making sub awards under covered
transactions to parties that are suspended or debarred. “Covered transactions” include those
procurement contracts for goods and services awarded under a non‐procurement transaction that
are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220.
Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320.
Condition
Verification of suspension and debarment was not performed for all vendors with whom the School
spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal
guidelines for purchases exceeding the small purchases threshold.
Cause
The School’s internal controls over procurement of goods and services were not adequate.
Effect
The School was not in compliance with federal regulations and guidelines related to suspension and
debarment or procurement.
Context
The School did not maintain documentation that a review to determine that vendors with whom the
School spent greater than $25,000 were not suspended and debarred. The deficiency applied to 3
vendors with the Indian School Equalization Program and 5 vendors with the Administrative Cost
Grants for Indian Schools. Additionally, for four vendors paid in excess of the small purchase
threshold ($10,000), the School deemed the procurement sole source; however, the School did not
prepare and maintain documentation for the sole source. The sample was not intended to be, and
was not, a statistically valid sample.
Recommendation
The School should review documented policies and implement them in school procedures to ensure
compliance with federal procurement requirements.
Views of Responsible Officials
See Corrective Action Plan.