Mifflinburg Area School District

Criteria: Under 2 CFR 200.318, non-federal entities are required to maintain documented procurement procedures that align with applicable federal, state, and local laws. Additionally, entities must ensure that all procurements provide full and open competition and take steps to utilize small and minority businesses, women's business enterprises, and labor surplus area firms when possible. Condition: The District's procurement policies do not comply with the federal procurement standards outlined in 2 CFR 200.318 through 200.327. Specifically, the policies lack adequate procedures to ensure full and open competition, and they do not include provisions addressing the use of small, minority-owned, and women-owned business enterprises as required by federal regulations. Cause: The District has not updated its procurement policies to reflect current federal requirements, which were revised under the Uniform Guidance. The lack of training and resources contributed to the oversight. Effect: Noncompliance with federal procurement standards could lead to questioned costs for expenditures under the Child Nutrition Cluster. It also incresaes the risk of noncompetitive practices and missed opportunities to engage small and disadvantaged businesses. Questioned Costs: Unknown. Recommendation: In order to correct the procurement process for Child Nutrition the client should revise the District's procurement policies to fully comply with 2 CFR 200.318 through 200.327, provide training for staff involved in procurement to ensure they understand and implement the updtaed policies, conduct periodic reviews of procurement activities to verify compliance with the revised policies, document efforts to engage small, minority-owned, and women-owned business enterprises in procurement activiites. Prior Year Finding: None. Auditee Response: See attached response.

Criteria: Under 2 CFR 200.318, non-federal entities are required to maintain documented procurement procedures that align with applicable federal, state, and local laws. Additionally, entities must ensure that all procurements provide full and open competition and take steps to utilize small and minority businesses, women's business enterprises, and labor surplus area firms when possible. Condition: The District's procurement policies do not comply with the federal procurement standards outlined in 2 CFR 200.318 through 200.327. Specifically, the policies lack adequate procedures to ensure full and open competition, and they do not include provisions addressing the use of small, minority-owned, and women-owned business enterprises as required by federal regulations. Cause: The District has not updated its procurement policies to reflect current federal requirements, which were revised under the Uniform Guidance. The lack of training and resources contributed to the oversight. Effect: Noncompliance with federal procurement standards could lead to questioned costs for expenditures under the Child Nutrition Cluster. It also incresaes the risk of noncompetitive practices and missed opportunities to engage small and disadvantaged businesses. Questioned Costs: Unknown. Recommendation: In order to correct the procurement process for Child Nutrition the client should revise the District's procurement policies to fully comply with 2 CFR 200.318 through 200.327, provide training for staff involved in procurement to ensure they understand and implement the updtaed policies, conduct periodic reviews of procurement activities to verify compliance with the revised policies, document efforts to engage small, minority-owned, and women-owned business enterprises in procurement activiites. Prior Year Finding: None. Auditee Response: See attached response.

Finding 2022-003 Equipment and Real Property Management Education Stabilization Fund (ESSER) ? ALN# 84.425 Criteria: Pursuant to 2 CFR part 200 section 439, capital expenditures for equipment are allowable as direct costs, provided that items with a unit cost of the lessor of $5,000 or the entity?s capitalization threshold have the prior written approval of the Federal awarding agency or pass-through entity. Furthermore, section 313(d)(1) specifies that property records must be maintained that include a description of the property, a serial or identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property. Condition: During testing, it was noted the District purchased two pieces of equipment over the capitalization threshold using ESSER funds without receiving prior approval from the Pennsylvania Department of Education. These assets were also not included in the District?s property records. Cause: Due to staff oversight, the District was not aware that certain costs needed to be pre-approved under the grant. Effect: Internal controls are not functioning as designed and the District is not in compliance with equipment and real property management requirements of the program. Questioned Costs: None Recommendation: The District should establish procedures to ensure all equipment purchased with grant funding is appropriately approved prior to purchase and property records are maintained in sufficient detail to allow for the adequate tracking of all equipment purchased with grant funds. Management?s Response: The District obtained guidance from PDE resources on the approval process for equipment over the capitalization threshold when utilizing ESSER funds. The District further identified its capitalization threshold of $1,500 is lower than the standard minimum capitalization threshold of $5,000. The capitalization policy will be updated. The value of any single item for inclusion in the fixed assets accounts shall be not less than $5,000 and have an estimated useful life of one (1) year or more.

Finding 2022-004 Reporting Education Stabilization Fund (ESSER) ? ALN# 84.425 Criteria: Pursuant to 2 CFR part 200 section 302(b)(2), a non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program. Condition: During testing, it was noted two of the four PDE-2030 reports did not contain accurate information as the expenditures reported did not agree to the District?s general ledger. Cause: Due to oversight, the District was not reporting expenditures on a cumulative basis. Effect: Internal controls are not functioning as designed and the District is not in compliance with reporting requirements of the program. Questioned Costs: None Recommendation: The District should develop procedures to ensure accurate information is reported to allow for adequate tracking of the financial results of each Federal award. In addition, reports should be reviewed by an appropriate individual prior to submission to ensure the data entered into the reports is consistent with the District?s records. Management?s Response: The District developed procedures for assigning expenditures for State and Federal awards and created reporting specific to funding sources to identify all awards. Prior to submissions to reporting agencies, quarterly and annual reports will be reviewed by the Business Administrator to ensure accuracy for the reporting period(s).