Finding 2023-001
significant deficiencyother matters
- Program
- EDUCATION STABILIZATION FUND (84.425)
- Compliance requirement
- Procurement and suspension and debarment
- FAC record
- FY2023 audit on fac.gov
Finding text from the filing
Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Repeat Finding: No Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425U Federal Agency: U.S. Department of Education Federal Award Number: 21528001075902 Pass‐Through Agency: Texas Education Agency Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition The District did not follow Federal, State, and Board policies and regulations governing procurement. Cause The District official responsible for making the purchase was not aware of the procurement compliance requirements. Additionally, those responsible for approving the purchase did not verify compliance. Effect The District was not in compliance with Federal, State, and Board policies and regulations governing procurement. Context The District procured computers, software licenses, and charging carts in the amount of $356,747 using quotations rather than issuing a formal procurement. Furthermore, the District did not check whether the vendor was suspended or debarred. Recommendation District employees who are delegated the authority to procure goods and services should receive training on Federal, State, and Board procurement policies and procedures. Additionally, approvers of requisitions should ensure purchases exceeding the formal procurement threshold are appropriately procured in accordance with Federal, State and Board policies and regulations. Views of Responsible Officials See Corrective Action Plan.