Monessen City School District

CONDITION: The School District of the City of Monessen contracted with a third-party vendor (TRANE) for the performance of a construction project at the District. The contract with the third-party vendor, which was procured through a cooperative purchasing group, exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. This is a repeat finding from the 2021-2022 fiscal year – Finding 2022-001. In addition, the District did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: 24 Pa. Statutes 751 of the Public School Code and Section 2 CFR 200.318(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a school district whereby the cost exceeds certain dollar thresholds as adjusted annually for an inflation index. The construction project exceeded the simplified acquisition threshold of $250,000. As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. CAUSE: School District personnel directly responsible for the oversight and execution of this contract interpreted that the requirements specified by 24 Pa. Statutes 751 of the Public School Code, and Sections 2 CFR 200.318(i) and 2 CFR 200.324(a) of the Uniform Guidance, would be met through the cooperative purchasing process based on an analysis of the documentation provided to them by the third-party vendor, however the District maintained no records internally to support this compliance. EFFECT: The School District of the City of Monessen did not comply with the requirements of 24 Pa. Statutes 751 of the Public School Code, and Sections 2 CFR 200.318(i) and 2 CFR 200.324(a) of the Uniform Guidance with regard to maintaining sufficient records to detail the history of procurement for the construction project and conducting a cost or price analysis for a procurement in excess of the Simplified Acquisition Threshold. QUESTIONED COST: $206,784 RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, in specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I recommend that the School District conduct a cost or price analysis for all procurement in excess of the Simplified Acquisition Threshold of $250,000 before receiving bids or proposals in accordance with Section 2 CFR 200.324(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).

CONDITION: The School District of the City of Monessen contracted with a third-party vendor (TRANE) for the performance of a construction project at the District. The contract with the third-party vendor, which was procured through a cooperative purchasing group, exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. This is a repeat finding from the 2021-2022 fiscal year – Finding 2022-001. In addition, the District did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: 24 Pa. Statutes 751 of the Public School Code and Section 2 CFR 200.318(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a school district whereby the cost exceeds certain dollar thresholds as adjusted annually for an inflation index. The construction project exceeded the simplified acquisition threshold of $250,000. As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.CRITERIA (Continued): In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. The timeframe for completion of this process will commence immediately with an anticipated completion date during the 2024-2025 fiscal year and will continue on an ongoing basis as required by new policy directives from oversight agencies. All future procurements will involve a collaboration between the District’s business office and federal programs department to ensure compliance with the District’s updated procurement policies.

2022-001

CONDITION: The School District of the City of Monessen does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. This is a repeat finding from the 2021-2022 fiscal year – Finding 2022-002 CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. The Uniform Guidance specifies six (6) affirmative action steps that must be taken. CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. EFFECT: The School District of the City of Monessen did not comply with the requirements of 2 CFR 200.321(a) of the Uniform Guidance with regard to required affirmative action steps to be employed in the procurement process.QUESTIONED COST: None RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) recommended affirmative action steps as stated in Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).

CONDITION: The School District of the City of Monessen does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible, in the procurement process. This is a repeat finding from the 2021-2022 fiscal year – Finding 2022-002. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. The Uniform Guidance specifies six (6) affirmative action steps that must be taken. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the School District, as a matter of policy, will implement the six (6) recommended affirmative action steps as stated in Section 2 CFR 200.321(a) of the Uniform Guidance. The timeframe for completion of this process will commence immediately with an anticipated completion date during the 2024-2025 fiscal year and will continue on an ongoing basis as required by new policy directives from oversight agencies. All future procurements will involve a collaboration between the District’s business office and federal programs department to ensure compliance with the District’s updated procurement policies.

2022-002

CONDITION: The School District of the City of Monessen contracted with Johnson Controls for fire alarm upgrades, and Dagostino Electronic Services for the installation of exterior cameras. These contracts individually exceeded the Uniform Guidance micro purchase threshold of $10,000, but did not exceed the Simplified Acquisition Threshold of $250,000. The District was unable to 1) provide records sufficient to detail the history of procurement for these two contracts and 2) provide documentation to verify that price or rate quotations were obtained from an adequate number of qualified sources. CRITERIA: 24 Pa. Statutes 8.807.1 and Section 2 CFR 200.320(a)(2)(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a non-federal entity whereby the cost exceeds certain dollar thresholds as adjusted periodically. In instances where the cost incurred exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, price or rate quotations must be obtained from an adequate number of qualified sources. In addition, as specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain sufficient records to detail the history of procurement. CAUSE: School District personnel directly responsible for the oversight and execution of these contracts were not fully familiar with the procurement requirements as prescribed by 24 Pa. Statutes 8.807.1, and Sections 2 CFR 200.320(a)(2)(i) and 2 CFR 200.318(i) of the Uniform Guidance. EFFECT: The School District of the City of Monessen did not comply with the requirements of 24 Pa. Statutes 8.807.1, and Sections 2 CFR 200.320(a)(2)(i) and 2 CFR 200.318(i) of the Uniform Guidance with regard to maintaining sufficient records to detail the history of procurement and conducting a cost or price analysis for a procurement in instances where the procurement cost incurred for goods and/or services exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000. QUESTIONED COST: $67,578 RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure In instances where the procurement cost incurred for goods and/or services exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, that 1) price or rate quotations are obtained from an adequate number of qualified sources, and 2) sufficient records are maintained to detail the history of procurement. These measures will enable the School District to comply with the procurement requirements as prescribed in 24 Pa. Statutes 8.807.1 and Section 2 CFR 200.320(a)(2)(i) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).

CONDITION: The School District of the City of Monessen contracted with Johnson Controls for fire alarm upgrades, and Dagostino Electronic Services for the installation of exterior cameras. These contracts individually exceeded the Uniform Guidance micro purchase threshold of $10,000, but did not exceed the Simplified Acquisition Threshold of $250,000. The District was unable to 1) provide records sufficient to detail the history of procurement for these two contracts and 2) provide documentation to verify that price or rate quotations were obtained from an adequate number of qualified sources. CRITERIA: 24 Pa. Statutes 8.807.1 and Section 2 CFR 200.320(a)(2)(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a non-federal entity whereby the cost exceeds certain dollar thresholds as adjusted periodically. In instances where the cost incurred exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, price or rate quotations must be obtained from an adequate number of qualified sources. In addition, as specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain sufficient records to detail the history of procurement. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the School District will review and update as necessary its procurement policies to ensure In instances where the procurement cost incurred for goods and/or services exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, that 1) price or rate quotations are obtained from an adequate number of qualified sources, and 2) sufficient records are maintained to detail the history of procurement. All future procurements will involve a collaboration between the District’s business office and federal programs department to ensure compliance with the District’s updated procurement policies.

CONDITION: The School District of the City of Monessen contracted with a third-party vendor (TRANE) for the performance of a construction project at the District. The contract with the third-party vendor, which was procured through a cooperative purchasing group, exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation.

MANAGEMENT?S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it?s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. The timeframe for completion of this process will commence immediately with an anticipated completion date of September 1, 2023, and will continue on an ongoing basis as required by new policy directives from oversight agencies. In addition, management will respond with additional measures considered necessary by the Pennsylvania Department of Education upon review of this finding and management?s corrective action plan.

CONDITION: The School District of the City of Monessen does not take affirmative action steps to assure that minority businesses, women?s business enterprises, and labor surplus area firms are used when possible, in the procurement process.

MANAGEMENT?S CORRECTIVE ACTION PLAN: Management of the School District, as a matter of policy, will implement the six (6) recommended affirmative action steps as stated in Section 2 CFR 200.321(a) of the Uniform Guidance. The timeframe for completion of this process will commence immediately with an anticipated completion date of September 1, 2023 and be implemented on all subsequent procurement instances that are applicable.