The Neighborhood House Charter School & Neighborhood House Charter School Foundation

Condition: The Organization?s procurement policy did not meet Federal guidelines which resulted in insufficient documentation relating goods and services procured with Federal funds during fiscal year 2019. Criteria: In accordance with CFR Part 215, the Organization must establish a procurement policy over purchases of goods and services with Federal funds. Effect: The Organization was not in compliance with Federal regulations during fiscal year 2019. Cause: Due to turnover in the business office over the past few years, the Organization?s procurement policy was not updated to be in compliance with the new Federal guidelines which were effective July 1, 2018. Recommendation: The Organization should establish a formal written purchasing manual describing detailed procedures relating to procurement of goods and services with Federal funds. The manual should describe detailed procedures which include, but are not limited to, the following: - Different types of goods and services used by the Organization. - Procedures to avoid acquisition of unnecessary or duplicative items. - Procedures to evaluate and document contractors? qualifications to ensure they possess the ability to perform successfully under the terms and conditions of the contract. - Establishing a process by which new suppliers are identified and pre-qualified to ensure the Organization maintains a competitive environment for making purchasing decisions. As a best practice, the list of pre-qualified vendors should be reviewed and updated on a regular basis (i.e. annually) to make sure enough qualified sources are included and the price quotes in the file are current. - Regularly evaluating and auditing pre-qualified suppliers for performance, including competitive pricing and user satisfaction. - Oversight of contractors? performance, who is responsible and how the Organization ensures such oversight is performed. - Procedure to perform timely, cost and price analysis for every procurement action in excess of the simplified acquisition threshold. - Procedures to address issues arising out of procurements, such as source evaluation, protests, disputes, and claims. - All necessary affirmative steps to assure that small and minority business (SMB), women?s business enterprises (WBE), and labor surplus area firms are used when possible. - Procedure for Requests for Proposals (RFP) and responsible person(s) who will assist in RFP and whether the RFP should be publicly advertised. - Provisions regarding the prohibition of geographical preference. Management Response: Subsequent to year end, the Organization revised their procurement policy to follow the Federal guidelines. This finding impacts the procurement, suspension and debarment requirement for CFDA #84.282 Charter Schools Program, passed through the Commonwealth of Massachusetts, Department of Elementary and Secondary Education. See Section 2 for detailed description of the finding.