Gallia County Local School District

Suspension and Debarment Finding Number: 2022-003 Assistance Listing Number and Title: AL# 32.009 Emergency Connectivity Fund Program Federal Award Identification Number / Year: 2022 Federal Agency: Federal Communications Commission Compliance Requirement: Section I- Procurement And Suspension And Debarment Pass-Through Entity: Direct Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR 180.305 states that Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred unless the Federal agency responsible for the transaction grants an exception under 2 CFR ? 180.135. ?Covered transactions? include nonprocurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR ? 180.220s. All nonprocurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR ? 180.215. When a non-Federal entity enters a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov), collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity. School District Policy DJF-R-2 - Purchasing Procedures (Procurement - Federal Grants/Funds), provides that the School District shall not subcontract with or award subgrants to any person or company who is debarred or suspended. For contracts over $25,000, the School District shall confirm that the vendor is not debarred or suspended by either checking the federal government?s System for Award Management, which maintains a list of such debarred or suspended vendors at www.sam.gov, collecting a certification from the vendor or adding a clause or condition to the covered transaction with that vendor (2 C.F.R. Part 180 Subpart C). The School District did not have the proper internal controls in place to verify that all entities, with whom the School District had entered into covered transactions, had not been suspended or debarred. During 2022 for the Emergency Connectivity Fund (ECF) Grant, the School District had one instance in which the program made a payment to a vendor of more than $25,000 and there was no evidence the School District checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed. The School District determined the vendor was not suspended or debarred but only after the contract was awarded. Failing to have the appropriate controls in place may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the School District should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

Noncompliance and Significant Deficiency Finding Number: 2020-002 CFDA Number and Title: CFDA # 10.555 - Nutrition Cluster CFDA # 84.010 - Title I Grants to Local Educational Agencies CFDA # 84.010A - School Quality Improvement Grant CFDA # 84.027 and 84.173 - Special Education Cluster CFDA # 84.358 - Rural Education CFDA # 84.367- Supporting Effective Instruction State Grants CFDA # 84.424 ? Student Support and Academic Enrichment Program Federal Award Identification Number / Year: 2019 / 2020 Federal Agency: U.S. Department of Education Compliance Requirement: Other Pass-Through Entity: Ohio Department of Education Repeat Finding from Prior Audit? No 2 CFR Subpart F ? 200.510(b) requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the School District's financial statements which must include the total federal awards expended as determined in accordance with ? 200.502. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the CFDA number or other identifying number when the CFDA information is not available. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in ? 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in ? 200.414 Indirect (F&A) costs. The following errors were noted in the Schedule of Expenditures of Federal Awards: ? CFDA # 10.555 did not include non-cash assistance of commodities in the amount of $109,934. ? CFDA # 84.010 did not include expenditures from SCC 9019 in the amount of $69,637. ? CFDA # 84.010 did not include expenditures for Bureau of Workers Compensation (BWC) premiums in the amount of $3,055. ? CFDA # 84.010A did not include expenditures from SCC 9120 in the amount of $56,084. ? CFDA # 84.027 did not include expenditures from Special Cost Center (SCC) 9019 in the amount of $28,198. ? CFDA # 84.027 did not include expenditures for Bureau of Workers Compensation (BWC) premiums in the amount of $483. ? CFDA # 84.173 did not include expenditures from SCC 9020 in the amount of $4,924. ? CFDA # 84.173 did not include expenditures from SCC 9120 in the amount of $2,712. ? CFDA # 84.358 did not include expenditures for Bureau of Workers Compensation (BWC) premiums in the amount of $20. ? CFDA # 84.367 did not include expenditures from SCC 9019 in the amount of $7,273. ? CFDA # 84.367 did not include expenditures for Bureau of Workers Compensation (BWC) premiums in the amount of $454. ? CFDA # 84.424 did not include expenditures from SCC 9119 in the amount of $6,129. ? CFDA # 84.424 did not include expenditures for Bureau of Workers Compensation (BWC) premiums in the amount of $323. Furthermore, the lack of effective controls over this compliance requirement resulted in the Schedule being misstated. Adjustments, to which management has agreed, are reflected in the Schedule. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agencies in addition to an inaccurate assessment of major federal programs that would be subjected to audit. School District management should review all grant documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The School District should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the School District is in compliance with grant requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit. the lack of effective controls over this compliance requirement resulted in the Schedule being misstated.