Finding 976670 (2023-003)

Material Weakness
Requirement
I
Questioned Costs
$1
Year
2023
Accepted
2024-06-07
Audit: 308341
Organization: Blackhawk School District (PA)

AI Summary

  • Core Issue: The District failed to document its rationale for a $26,667 purchase from Western PA Psych Care, violating procurement guidelines.
  • Impacted Requirements: Noncompliance with Section 2 CFR 200.318(i) and Section 2 CFR 200.320(c) of the Uniform Guidance, as well as District Procurement Policy #626.
  • Recommended Follow-Up: Ensure future noncompetitive procurements follow both the District’s Procurement Policy (#626) and the relevant Uniform Guidance requirements.

Finding Text

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Western PA Psych Care’ totaling $26,667. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance, and District Procurement Policy #626, regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: $26,667 CAUSE: The District has had a long-standing relationship with Western PA Psych Care and feels that this vendor best fits the needs of the District. However, the additional procedures addressed in its Procurement Policy for Federal Programs (#626) which addresses the issue of noncompetitive procurement as outlined in Section 2 CFR 200.320(c’), were inadvertently not performed. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 400227 2023-002
    Material Weakness
  • 400228 2023-003
    Material Weakness
  • 400229 2023-002
    Material Weakness
  • 400230 2023-002
    Material Weakness
  • 976669 2023-002
    Material Weakness
  • 976671 2023-002
    Material Weakness
  • 976672 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States $344,321
10.553 School Breakfast Program $130,302
10.555 National School Lunch Program $82,516
84.010 Title I Grants to Local Educational Agencies $48,153
84.425 Education Stabilization Fund $22,481
93.778 Medical Assistance Program $5,852
84.367 Improving Teacher Quality State Grants $5,594
84.424 Student Support and Academic Enrichment Program $3,139
10.649 Pandemic Ebt Administrative Costs $628
84.173 Special Education_preschool Grants $518