Finding 2025-001
significant deficiencyother matters
- Program
- SPECIAL EDUCATION CLUSTER (IDEA) (84.027)
- Compliance requirement
- Procurement and suspension and debarment
- FAC record
- FY2025 audit on fac.gov
Finding text from the filing
Type of Findings: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party.
Condition: During our review we noted that the district followed procurement guidelines and policies established in the DJB Federal Procurement guide, but the District does not have an established suspension and debarment policy that they follow. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party.
Questioned costs: None
Context: The sole vendor engaged under the IDEA grant was found to have no evidence of verification that the vendor was not suspended or debarred by the District. We did later verify that the vendor was not suspended or debarred per verification on SAM.gov.
Cause: The District engaged with the vendor in a contract effective from 07/01/2023, but did not conduct a suspension and debarment check prior to engagement.
Effect: The District could not be in compliance with suspension and debarment requirements for its federal programs.
Repeat Finding: No
Recommendation: We recommend that the District implement policies for verifying suspension and debarment compliance for all transactions with vendors that are paid with Federal Funds.
View of Responsible Officials: There is no disagreement with the audit finding.
Corrective action plan - management response: The District will formally adopt a Suspension and Debarment Verification Procedure that outlines the required process for verifying all vendors and subrecipients before entering into any contract funded by federal awards.
Staff will verify suspension and debarment status by checking the System for Award Management (SAM.gov) prior to contract execution and will maintain documentation of verification in the procurement file.
The Business Services Department will complete training on the new procedure and documentation requirements.
Responsible Party: Business Manager
Completion Date: Procedure adoption and staff training by December 31, 2025