Finding Text
CONDITION: The Greensburg Salem School District contracted with a third-party vendor (Trinity
Automated Solutions, Inc.) for the performance of a HVAC Upgrades construction project at the District.
The contract with the third-party vendor, which was procured through a cooperative purchasing group,
exceeded the threshold for competitive procurement. The District was unable to provide documentation
to verify that the third-party procurement contract was competitively procured, such as a bid evaluation
and public solicitation.
During the year ended June 30, 2023, as a result of a monitoring performed by the Pennsylvania
Department of Education, it was decided the District would use local funds to pay for project costs
previously recognized and charged to the Elementary and Secondary School Emergency Relief Fund
(ESSER III) federal program. As a result, prior year revenues recognized had to be reclassified as
unearned revenues and beginning fund balance/net position are restated. The district additionally
reclassified the Trinity Project from a Federal purchase and will not submit it as an expenditure through
the Federal ESSER funding for the 2023 fiscal year. Refer to Note 13 within the financial statements.
CRITERIA: 24 Pa. Statutes 751 of the Public School Code and Section 2 CFR 200.318(i) of the Uniform
Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a
school district whereby the cost exceeds certain dollar thresholds as adjusted annually for an inflation
index. The HVAC Upgrades construction project exceeded the simplified acquisition threshold of
$250,000. As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records
sufficient to detail the history of procurement. These records will include, but are not necessarily limited
to, the following: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
EFFECT: The Greensburg Salem School District did not comply with the requirements of 2 CFR
200.318(i) of the Uniform Guidance with regard to maintaining records sufficient to detail the history of
procurement for the HVAC Upgrades construction project.
Subsequent to the issuance of the prior year audit, the District decided to use local funds for the project
instead of the federal funds previously recognized. As a result, beginning fund balance/net position had to
be restated for the previously recognized federal revenue.
IDENTIFICATION OF A REPEAT FINDING: This is a repeat finding from the immediate previous audit,
2022-001.
RECOMMENDATION: Management of the School District should review and update as necessary its
procurement policies to ensure retention of the appropriate procurement documentation, in all instances,
including such instances whereby the District complies with all applicable sections of the Uniform
Guidance.