Finding Text
2023-004: U.S. Department of Education
Passed through State of Nevada Department of Education
Special Education Cluster (IDEA)
Special Education Grants to States, 84.027
COVID-19, Special Education Grants to States, 84.027
Special Education Preschool Grants, 84.173
COVID-19, Special Education Preschool Grants, 84.173
U.S. Department of Agriculture
Passed through State of Nevada Department of Agriculture
Child Nutrition Cluster
School Breakfast Program, 10.553
National School Lunch Program, 10.555
Fresh Fruit and Vegetable Program, 10.582
U.S. Department of Treasury
Passed through State of Nevada Department of Education and the State of Nevada
Department of Agriculture
COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027
Procurement, Suspension and Debarment
Material Weakness in Internal Control over Compliance and Material Noncompliance
Grant Award Number: Affects all grant awards included under assistance listing numbers 84.027, 84.173, 10.553, 10.555, 10.582, and 21.027 on the Schedule of Expenditures of Federal Awards.
Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires procurement processes for acquiring goods and services over $10,000 include obtaining rate quotations, otherwise sole source vendor documentation must be maintained.
Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Procurement processes required for acquiring goods and services were not followed. Procedures were not followed to maintain documentation regarding the verification of whether an entity was suspended or debarred before entering into a covered transaction.
Cause: Elko County School District did not have adequate internal controls to ensure that procurement processes were followed relating to obtaining rate quotations or to verify subrecipients were not suspended or debarred prior to entering into a covered transaction.
Effect: Procurement policies are not adhered to. A covered transaction may be entered into with an entity or subrecipient that is suspended or debarred.
Questioned Costs: None
Context/Sampling: Special Education Cluster (IDEA), 84.027 and 84.173
A nonstatistical sample of four vendors which had purchases over the micropurchase threshold over $10,000 for the fiscal year out of a population of ten vendors meeting this criteria were selected for testing. For all four vendors there was no documented rate quotations or single source vendor documentation maintained or evidence of verification if the parties were suspended or debarred.
Child Nutrition Cluster, 10.553, 10.555 and 10.582
All vendors which had purchases over the micro-purchase threshold over $10,000 for the fiscal year were selected for testing as the population was three. For two vendors there was no documented rate quotations or single source vendor documentation maintained or evidence of verification if the parties were suspended or debarred.
COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027
A nonstatistical sample of five vendors which had purchases over the micropurchase threshold over $10,000 for the fiscal year out of a population of 25 vendors meeting this criteria were selected for testing. There were four vendors with no documented rate quotations or single source vendor documentation maintained or evidence of verification if the parties were suspended or debarred.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend Elko County School District implement internal control policies to follow required procurement processes including obtaining rate quotations and ensuring entities are not suspended or debarred prior to entering into covered transactions.
Views of Responsible Officials: Management agrees with the finding.