Chartiers-Houston School District

Criteria - The ?Reconciliation of Cash on Hand? quarterly reports are to be remitted within the 10th working day following the quarter of when eligible federal expenditures are incurred. Condition - 2 CFR 200.329 The district did not timely report to Pennsylvania Department of Education (PDE) eligible federal expenditures for reimbursement that were incurred during a three-month period throughout the year. Cause/Effect Cause of the Finding ? The district experienced a change of business manager during the school year. During the transition, certain duties of the business office were not completed. Effect of the Finding ? The opportunity cost of managing cashflow of the district due to not receiving reimbursement of federal expenditures in a timely manner. Also, PDE Financial and Account Information (FAI) portal may suspend payment until reporting status is updated. Questioned Costs ? No questioned costs. Recommendations - Report eligible federal expenditure for reimbursement in a timely manner. District?s Response - The district?s administration agrees with this finding. The process of reporting eligible federal expenditures will be modified to ensure requests for reimbursement occur in a timely manner.

Criteria - 2 CFR 200.318 A component of compliance relating to federal awards is maintaining records sufficient to detail the history of procurement. These records will include, but are not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition - The District used federal ESSER funds to make purchases greater than $10,000 to $21,900 without obtaining at least three quotes and made purchases greater than $21,900 without obtaining three public bids. Cause/Effect Cause of the Finding ? There was a breakdown in the previously established purchasing policy relating to obtaining quotes and bid requirements. In addition, the district was under the false notion that purchases made through the Commonwealth of Pennsylvania?s cooperative purchasing program COSTARS and PEPPM satisfied compliance requirement of quote/bid requirements for federal purchases. Effect of the Finding ? The District was not in compliance with procurement requirements for federal funds. Questioned Costs ? Total questioned costs - $793,135 - Purchases made under the false notion that PEPPM satisfied the three?quote requirement total $16,365 (2% of ESSERS expense), purchases made under the false notion that COSTAR satisfied the three-bid requirement total $401,962 (43% of ESSERS expense), and purchases that were made outside co-purchasing arrangements and did not satisfy three-bid requirement total $374,805 (40% of ESSERS expense). Recommendations - The Uniform Guidance establishes thresholds of when quote and bids are to be obtained from vendors. Documentation is key for all federal purchases. A purchase price from cooperative purchasing programs can be considered one competitive price proposal and cannot replace a procurement process. Advertise when appropriate, obtain adequate quote/bid information from three vendors, and thoroughly document the ?reason? and ?cost analysis? of sole source noncompetitive procurement exceptions. District?s Response - The district will follow the policy for quotation/bid requirements for federal purchases and not use cooperative purchasing programs as the only source of quotations/bids for federal purchases. The district will also improve documentation relating to purchases that meet sole source criteria.