Finding Text
Finding 2023-001
Significant Deficiency and Material Instance of Non-Compliance
Procurement Policy
This finding impacts the procurement and suspension and debarment compliance requirement forthe major program, Assistance Listing Number 84.282 Charter Schools (CSP), funded by the U.S. Department of Education and passed-through by the Commonwealth of Massachusetts Department of Elementary and Secondary Education (DESE).
Criteria: The School must follow the procurement standards set out at 2 CFR Sections 200.317. through 200.327. The School also must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statues and the procurement requirements identified in 2 CFR part 200.
Condition: As part of testing the School’s compliance with Uniform Guidance procurement standards, we reviewed the School’s procurement policy against Uniform Guidance standards and tested three transactions totaling approximately $378,000 for evidence of competitive bids. While the School maintains a procurement policy in accordance with Uniform Guidance standards, the School did not maintain evidence of bids in accordance with its procurement policy.
Cause: The School had a limited amount of time to apply for and spend the CSP funds and open its high school with the goods that were purchased. This led to the School not following its existing procurement policy.
Effect: Non-compliance with the Uniform Guidance, potentially resulting in a decrease in Federal Funding. The finding did not result in any questioned costs as evidence of purchases was maintained.
Repeat Finding: No.
Recommendation: AAFCPAs recommends that management follows its procurement policy which complies with Uniform Guidance.
Management Response: Management prioritized being equipped for the opening of school with students when faced with a tight timeline to apply for and expend grant funds. In a time when delays on goods and services were normalized, management moved forward with a furniture order that met all of our operational needs including a guaranteed delivery timeline that included assembly and setup as well as the quality and aesthetic of the furniture we were confident with. In doing so, we did not ensure full compliance with the School's procurement process. Management remains confident in the School's procurement policies and if ever a similar, albeit atypical, situation should arise we will ensure compliance with the School's procurement policies. Management understands that following the School's procurement policy, which complies with Uniform Guidance, is necessary so as not to jeopardize future funding opportunities.