DC Bilingual Public Charter School

2019-001 U.S. Department of Education ? DC School Choice Incentive Program - CFDA# 84.370C Criteria and Condition: Non-federal organizations are prohibited from contracting with or making subawards to parties that are debarred or whose principals are suspended or debarred from performing under a federal award. When a non-federal organization enters into a contract with a party for goods or services in an amount greater than $25,000, or enters into a subrecipient agreement irrespective of the award amount, the organization must verify that the entity and its principals are not suspended or debarred or otherwise excluded from participating in a federal award. The DC Bilingual Public Charter School did not fully comply with the requirements as it relates to "Debarred and Suspended Parties." Questioned Costs $ 0 Context: During the year ended June 30, 2019, the DC Bilingual Public Charter School entered into a contract for services where federal funds were utilized for the payment of such services. The Charter School did not utilize recommended procedures to ensure that the subcontractor was eligible for contracting in the federal award program. An audit sample of one (1) subcontractor was selected to verify that the subcontractor certified that they were not debarred or suspended from working on a federal program. Evidence did not exist for the subcontractor indicating they were not debarred or suspended during the year ended. Cause: During the year ended June 30, 2019, the DC Bilingual Public Charter School started a new project for construction renovations, and Management was unaware of this federal requirement. Effect: Not obtaining the proper evidence to ensure that a party is not debarred or suspended from doing work on a federal award could ultimately result in the DC Bilingual Public Charter School awarding a subcontract to an ineligible party. Recommendation: The Federal agency recommends that debarred and suspended verification be accomplished through one of three methods. These methods include (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a separately executed certification from the entity, or (3) adding a clause or condition to the actual subcontract agreement with the contracting party. We recommend the use of option number 2 or 3 above over option number 1 because it provides better assurance that not only is the organization permitted to participate in a federal award, but the principals are also permitted to work under a federal grant. Views of Responsible Officials: The DC Bilingual Public Charter School will revise its procurement policies and procedures governing contracts that utilize federal funds to require a debarred party certification from each vendor.