EIN: 436003220
UEI: KSAZCPTPXPW9
Audited by: RUBINBROWN LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 29, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 29, 2026 (26 days from today).
What is a management decision? →The District did not perform a review prior to submission. The District does not have controls in place to ensure reporting is properly supported by lunch count data. Cause: The District did maintain the lunch count data and submit required reports. However, two of the four reports tested did not agree to lunch count data. Effect Or Potential Effect: The District is not in compliance with the Uniform Guidance compliance requirements regarding reporting. Questioned Costs: $7,941 of known and $40,015 of likely questioned costs Context: Of the four reports tested, two were submitted with inaccurate lunch count data. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that the District implement procedures and controls to ensure review and reconciliation of claims reports take place to agree to lunch count data in accordance with the Uniform Guidance. Views Of Responsible Officials: Management agrees with the finding and is actively developing a reconciliation process to review and reconcile the lunch count data and ensure accuracy prior to submitting claims for reimbursement. This will ensure the district is following Uniform Guidance.
Show full finding ▾Hide full finding ▴Finding No. 2025-008 Significant Deficiency: Reporting - Compliance and Control Finding ALN 10.555, 10.553, 10.582, 10.559 - Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture Pass-Through Entity: Missouri Department of Elementary and Secondary Education Criteria Or Specific Requirement: According to Uniform Guidance, 2 CFR Section 210.8(a)(2), prior to the submission of a monthly Claim for Reimbursement, each school food authority shall review the lunch count data for each school under its jurisdiction to ensure the accuracy of the monthly Claim for Reimbursement. Condition: The District did not perform a review prior to submission. The District does not have controls in place to ensure reporting is properly supported by lunch count data. Cause: The District did maintain the lunch count data and submit required reports. However, two of the four reports tested did not agree to lunch count data. Effect Or Potential Effect: The District is not in compliance with the Uniform Guidance compliance requirements regarding reporting. Questioned Costs: $7,941 of known and $40,015 of likely questioned costs Context: Of the four reports tested, two were submitted with inaccurate lunch count data. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that the District implement procedures and controls to ensure review and reconciliation of claims reports take place to agree to lunch count data in accordance with the Uniform Guidance. Views Of Responsible Officials: Management agrees with the finding and is actively developing a reconciliation process to review and reconcile the lunch count data and ensure accuracy prior to submitting claims for reimbursement. This will ensure the district is following Uniform Guidance.
Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement procedures for review and reconciliation of lunch count data with claims reports in accordance with the Uniform Guidance.
The District did not obtain prior approval from DESE for purchasing capital expenditures that were not included on DESE’s preapproved list of capital expenditures. Approval was obtained subsequent to the spending of funds. Cause: The District incurred capital expenditures in March 2025 with federal funding without obtaining prior approval. Effect Or Potential Effect: The District is not in compliance with the Uniform Guidance compliance requirements regarding allowable costs and activities. Questioned Costs: Not Applicable Context: Of the 40 transactions tested, 23 transactions were identified as costs requiring prior approval. These costs were charged to the Child Nutrition Cluster during the period of July 1, 2024 through June 30, 2025. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that the District implement procedures and controls to ensure pre-approval is obtained prior to the expenditure of federal funding. Views Of Responsible Officials: Management agrees with the finding and is implementing procedures and controls to ensure pre-approval of required expenditures. This will ensure the district is following Uniform Guidance compliance requirements.
Show full finding ▾Hide full finding ▴Finding No. 2025-009 Material Weakness: Activities Allowed and Unallowed - Compliance and Control Finding ALN 10.555, 10.553, 10.582, 10.559 - Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture Pass-Through Entity: Missouri Department of Elementary and Secondary Education Criteria Or Specific Requirement: According to 2 CFR Section 210.19(a)(1), the District must comply with the accounting requirements for all revenues and expenditures of their nonprofit school food service. Capital expenditures are allowed but require Missouri Department of Elementary and Secondary Education’s (DESE) approval. Condition: The District did not obtain prior approval from DESE for purchasing capital expenditures that were not included on DESE’s preapproved list of capital expenditures. Approval was obtained subsequent to the spending of funds. Cause: The District incurred capital expenditures in March 2025 with federal funding without obtaining prior approval. Effect Or Potential Effect: The District is not in compliance with the Uniform Guidance compliance requirements regarding allowable costs and activities. Questioned Costs: Not Applicable Context: Of the 40 transactions tested, 23 transactions were identified as costs requiring prior approval. These costs were charged to the Child Nutrition Cluster during the period of July 1, 2024 through June 30, 2025. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that the District implement procedures and controls to ensure pre-approval is obtained prior to the expenditure of federal funding. Views Of Responsible Officials: Management agrees with the finding and is implementing procedures and controls to ensure pre-approval of required expenditures. This will ensure the district is following Uniform Guidance compliance requirements.
Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement procedures and controls to ensure pre-approval in accordance with the Uniform Guidance compliance requirements.
FAC accepted this audit on May 19, 2025 — management decision was due November 19, 2025.
The District did not perform a physical inventory over a two-year period. The District does not have controls in place to ensure bi-annual inventories will be performed to capture equipment purchase with federal funds. Cause: The District did maintain a property and equipment listing for federally funded purchases, however, there was no supporting documentation to demonstrate that a bi-annual inventory was performed. The District has two inventory technicians and equipment is maintained at over sixty locations. The staffing was not sufficient to ensure bi-annual could be completed within the proper timeframe. Effect Or Potential Effect: The District is not in compliance with the Uniform Guidance compliance requirements regarding equipment management. Questioned Costs: Not applicable. Context: No evidence could be obtained to verify a bi-annual inventory was performed. Identification As A Repeat Finding: 2023-004 Recommendation: We recommend that the District implement procedures and controls to ensure bi-annual inventories are performed in accordance with the Uniform Guidance. Views Of Responsible Officials: The District capitalization policy requires a periodic inventory of all capital assets. Inadequate staffing prevented the physical inventory for the fiscal year, but the district will seek assistance of an asset services firm for the next fiscal year and thereafter as needed.
Show full finding ▾Hide full finding ▴Finding No. 2024-005 Significant Deficiency: Equipment and Real Property Management – Compliance and Control Finding ALN 84.425 – COVID-19: Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Missouri Department of Elementary and Secondary Education Criteria Or Specific Requirement: According to Uniform Guidance, 2 CFR Section 200.313 (d)(2), a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition: The District did not perform a physical inventory over a two-year period. The District does not have controls in place to ensure bi-annual inventories will be performed to capture equipment purchase with federal funds. Cause: The District did maintain a property and equipment listing for federally funded purchases, however, there was no supporting documentation to demonstrate that a bi-annual inventory was performed. The District has two inventory technicians and equipment is maintained at over sixty locations. The staffing was not sufficient to ensure bi-annual could be completed within the proper timeframe. Effect Or Potential Effect: The District is not in compliance with the Uniform Guidance compliance requirements regarding equipment management. Questioned Costs: Not applicable. Context: No evidence could be obtained to verify a bi-annual inventory was performed. Identification As A Repeat Finding: 2023-004 Recommendation: We recommend that the District implement procedures and controls to ensure bi-annual inventories are performed in accordance with the Uniform Guidance. Views Of Responsible Officials: The District capitalization policy requires a periodic inventory of all capital assets. Inadequate staffing prevented the physical inventory for the fiscal year, but the district will seek assistance of an asset services firm for the next fiscal year and thereafter as needed.
Finding 2024-005 Personnel Responsible for Corrective Action: Kim Johnson, SLPS Chief Financial Officer/Treasurer and Kelly Genge, Controller Anticipated Completion Date: June 30, 2025 Corrective Action Plan: The finance department engaged an asset services firm to perform a physical inventory of the District’s capital assets during fiscal year 2025.
2023-004
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
The District did not perform a physical inventory over a two-year period. The District does not have controls in place to ensure bi-annual inventories will be performed to capture equipment purchase with federal funds. Cause: The District did maintain a property and equipment listing for federally funded purchases, however, there was no support a bi-annual inventory was performed. The District has two inventory technicians and equipment is maintained at over sixty locations. The staffing was not sufficient to ensure bi-annual could be completed within the proper timeframe. Effect Or Potential Effect: The District is not in compliance with the Uniform Guidance compliance requirements regarding equipment management. Questioned Costs: Not applicable. Context: No evidence could be obtained to verify a bi-annual inventory was performed. Identification As A Repeat Finding: N/A Recommendation: We recommend that the District implement procedures and controls to ensure bi-annual inventories are performed in accordance with the Uniform Guidance. Views Of Responsible Officials: The District capitalization policy requires a periodic inventory of all capital assets. Inadequate staffing prevented the physical inventory for the fiscal year, but the finance department will seek assistance of an asset services firm for the next fiscal year and thereafter as needed.
Show full finding ▾Hide full finding ▴Finding No. 2023-004 Significant Deficiency: Equipment and Real Property Management – Compliance and Control Finding ALN 84.425 – COVID-19: Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Missouri Department of Elementary and Secondary Education Criteria Or Specific Requirement: According to Uniform Guidance, 2 CFR Section 200.313 (d)(2), a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition: The District did not perform a physical inventory over a two-year period. The District does not have controls in place to ensure bi-annual inventories will be performed to capture equipment purchase with federal funds. Cause: The District did maintain a property and equipment listing for federally funded purchases, however, there was no support a bi-annual inventory was performed. The District has two inventory technicians and equipment is maintained at over sixty locations. The staffing was not sufficient to ensure bi-annual could be completed within the proper timeframe. Effect Or Potential Effect: The District is not in compliance with the Uniform Guidance compliance requirements regarding equipment management. Questioned Costs: Not applicable. Context: No evidence could be obtained to verify a bi-annual inventory was performed. Identification As A Repeat Finding: N/A Recommendation: We recommend that the District implement procedures and controls to ensure bi-annual inventories are performed in accordance with the Uniform Guidance. Views Of Responsible Officials: The District capitalization policy requires a periodic inventory of all capital assets. Inadequate staffing prevented the physical inventory for the fiscal year, but the finance department will seek assistance of an asset services firm for the next fiscal year and thereafter as needed.
Finding 2023‐004 Personnel Responsible for Corrective Action: Charles Ellis, SLPS Fiscal Control Director Anticipated Completion Date: August 30, 2024 Corrective Action Plan: The finance department will engage an asset services firm to perform a physical inventory of the District’s capital assets for fiscal year 2024.
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Yes. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions. Views Of Responsible Officials: The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.
Show full finding ▾Hide full finding ▴Finding No. 2022-002 Significant Deficiency: Procurement, Suspension And Debarment ? Control Finding Federal Award Information: U.S. Department of Education, Special Education Cluster, passed through the Missouri Department of Elementary and Secondary Education ALN: 84.027 and 84.173 - Special Education Cluster Criteria: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into 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 from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Yes. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions. Views Of Responsible Officials: The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.
Finding 2022-002 Personnel Responsible For Corrective Action: Stephanie Piatt, SLPS Interim Procurement Director Anticipated Completion Date: January 1, 2023 Corrective Action Plan: Create a Procurement Department procedure for checking the System for Award Management (SAM to ensure potential vendors are in Good Standing with the Federal Government before awarding Saint Louis Public Schools? contracts. Generate and maintain SAM?s vendor record searches as evidence of procurement policy compliance. The District will do the following: - The Procurement Team will update the mandatory requirement list to include documentation from the contractor or entity stating that the entity is not suspended or debarred - The Buyer/Analyst will review all Request for Proposal (RFPs), and Request for Qualifications (RFQs) and contract documentation submissions via the RFP/Contract checklist. - The Buyer/Analyst will save a copy of the SAM status report on Microsoft one drive, so that all members of the Procurement team will have access. - The Procurement Director will provide a secondary review of the RFPs, RFQs and contracts against the checklist to ensure that that all mandatory documents have been received. -The Procurement Director will submit the contract for review to the Superintendent or CFO for final signature. - A SAM clause will be added to existing contracts. Pending approval from our internal legal department. - Generate and maintain SAM?s vendor record searches as evidence of procurement policy compliance. All potential vendor required to register with sam.gov upon vendor registration. - Review quarterly the following: Request for Proposals (RFPs) Request for Qualifications (RFQs), Grant related Contracts Awards, and SAM?s vendor record submissions.
2021-002
The signed equipment use agreement related to the student?s remote connectivity was not retained. This agreement should be obtained for any student that checks out equipment through the District and retained. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that an ineligible student could receive wireless service through a connected device, or exceed the limit on the number of connected devices. Questioned Costs: Not applicable. Context: Internal controls as designed by the District were to ensure students signed the use agreement for equipment checked out. A signed use agreement was unable to be located for 21 out of 40 students tested for equipment and real property and special test and provision requirements. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The District will review and adjust the current process and make necessary adjustments to ensure each student with an ECF device will have the necessary documentation in their file. The District will also develop an additional contract to distinguish between an ECF device versus a regular district issued device.
Show full finding ▾Hide full finding ▴Finding 2022-003 Significant Deficiency: Equipment and Real Property Management ? Control Finding; Special Test and Provisions: Restricted Purpose - Control Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: The signed equipment use agreement related to the student?s remote connectivity was not retained. This agreement should be obtained for any student that checks out equipment through the District and retained. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that an ineligible student could receive wireless service through a connected device, or exceed the limit on the number of connected devices. Questioned Costs: Not applicable. Context: Internal controls as designed by the District were to ensure students signed the use agreement for equipment checked out. A signed use agreement was unable to be located for 21 out of 40 students tested for equipment and real property and special test and provision requirements. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The District will review and adjust the current process and make necessary adjustments to ensure each student with an ECF device will have the necessary documentation in their file. The District will also develop an additional contract to distinguish between an ECF device versus a regular district issued device.
Finding 2022-003 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The Information Technology Department will revise the Technology Issue and Reclamation Plan to include two reconciliation periods, one after technology issuance in the summer/fall, and the other after technology reclamation in the spring/summer, to ensure that all contracts and documentation accounted for have the correct corresponding contract in the devices profile in the database where the documents are kept.
For 6 of 40 students that checked out equipment, student profiles that stated if equipment was returned was unable to be provided. Cause: Controls over compliance put in place by management were not operating effectively as it relates to this compliance requirement. Effect: The possibility exists that a student could exceed the limit on the number of checked out connected devices as regulated by the federal agency. Questioned Costs: Not applicable. Context: Internal controls as designed by the District to ensure that per location and per user limits of equipment that is checked out by students is properly recorded in the system and tracked through the return process were not operating effectively. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The Information Technology Department will revise the current process for returning equipment so that if an ECF device is not returned, the student?s profile in SIS will reflect the type of device not returned and be issued a District on-site device only. The student?s profile for the ensuing fiscal year will then reflect that the student will be eligible for an on-site device District device only.
Show full finding ▾Hide full finding ▴Finding 2022-004 Significant Deficiency: Special Tests and Provisions: Restricted Purpose ? Control and Compliance Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: The compliance provisions of the federal program limit the amount of equipment that one student is able to have. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program related to special tests and provision requirements. Condition: For 6 of 40 students that checked out equipment, student profiles that stated if equipment was returned was unable to be provided. Cause: Controls over compliance put in place by management were not operating effectively as it relates to this compliance requirement. Effect: The possibility exists that a student could exceed the limit on the number of checked out connected devices as regulated by the federal agency. Questioned Costs: Not applicable. Context: Internal controls as designed by the District to ensure that per location and per user limits of equipment that is checked out by students is properly recorded in the system and tracked through the return process were not operating effectively. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The Information Technology Department will revise the current process for returning equipment so that if an ECF device is not returned, the student?s profile in SIS will reflect the type of device not returned and be issued a District on-site device only. The student?s profile for the ensuing fiscal year will then reflect that the student will be eligible for an on-site device District device only.
Finding 2022-004 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: During the revise Information Technology reclamation process, students with ECF devices that do not return the device will be noted in SIS to not have returned an ECF device. The device will be locked through the Moysle system and can be traceable, and the student?s profile in SIS will indicate that they are eligible to receive a District only device that is retained at each school site if the student/family doesn?t start a payment plan to pay for the device that was not returned.
Reimbursement request was not prepared and submitted until December 2022, even though 60 days after the last service date was August 2022. Cause: Management did not have an internal control process in place to ensure timely submission of the reimbursement request. Effect: The possibility exists that noncompliance with federal requirements could go undetected, and the federal agency could deny the request for reimbursement, without proper controls over compliance. Questioned Costs: Not applicable. Context: Reimbursement request was submitted in December 2022 and the federal agency funded the request in December 2022. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The Information Technology Department will provide all necessary grant paperwork to the Finance Office to ensure that all applicable deadlines are met, and that reimbursement happens in the allotted time period.
Show full finding ▾Hide full finding ▴Finding 2022-005 Significant Deficiency: Period of Performance ? Control and Compliance Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: The compliance provisions of the federal program require that final expense reimbursements take place within 60 days of the last service date. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program related to special tests and provision requirements. Condition: Reimbursement request was not prepared and submitted until December 2022, even though 60 days after the last service date was August 2022. Cause: Management did not have an internal control process in place to ensure timely submission of the reimbursement request. Effect: The possibility exists that noncompliance with federal requirements could go undetected, and the federal agency could deny the request for reimbursement, without proper controls over compliance. Questioned Costs: Not applicable. Context: Reimbursement request was submitted in December 2022 and the federal agency funded the request in December 2022. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The Information Technology Department will provide all necessary grant paperwork to the Finance Office to ensure that all applicable deadlines are met, and that reimbursement happens in the allotted time period.
Finding 2022-005 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The Information Technology Department will schedule a call with the ECF consultant, the Financial Management Office, and the Fiscal Control Office by July 15, 2023 to discuss all necessary paperwork that will be submitted to the Financial Management and Fiscal Control Offices 30 days prior to the final submission deadline to ensure that all payment requests can be submitted in the allotted time period, and give the Finance Offices understanding of what the reimbursement amount will be. The ECF consultant will copy the Chief Financial Officer, Finance Director, Grants Manager, and Fiscal Control Director on his/her submission.
FAC accepted this audit on January 16, 2022 — management decision was due July 16, 2022.
The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing.Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions.Views of Responsible Officials: The District agrees with this finding. The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.
Show full finding ▾Hide full finding ▴Finding No. 2021-002 Significant Deficiency: Procurement, Suspension and Debarment Federal Award Information: U.S. Department of Education, School Improvement Grants, passed through the Missouri Department of Elementary and Secondary Education ALN: 84.377 Criteria: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into 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 from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing.Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions.Views of Responsible Officials: The District agrees with this finding. The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.
Finding 2021-002 Personnel Responsible for Corrective Action: Robert Horton, SLPS Procurement Director Anticipated Completion Date: December 31, 2021 Corrective Action Plan: Create a Procurement Department procedure for checking the System for Award Management (SAM to ensure potential vendors are in Good Standing with the Federal Government before awarding Saint Louis Public Schools? contracts. Generate and maintain SAM?s vendor record searches as evidence of procurement policy compliance.
FAC accepted this audit on January 6, 2021 — management decision was due July 6, 2021.
FAC accepted this audit on January 14, 2020 — management decision was due July 14, 2020.
Federal Award Information: U.S. Department of Education, Special Education Cluster, passed through the Missouri Department of Elementary and Secondary Education CFDA No: 84.027 and 84.173 Federal Award ID: H027A170040, H027A180040, H173A180103 Compliance Requirement: Procurement and Suspension and Debarment Criteria: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into 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 from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition/Context: The District did not maintain documentation to support that suspension or debarment verification was performed prior to contracting or making covered transactions to entities. A certification or clause in the vendor contracts was also not required by the District. This deficiency was noted in the two covered transactions sampled out of the population of five. Statistical sampling method was not used. Both covered transactions were entered into with vendors who were not suspended or debarred. Questioned Costs: Undeterminable Cause: The District?s internal control over compliance did not operate effectively. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the samples selected. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Repeat Finding: No Recommendation: We recommend that the District adhere to their policy and maintain support that a SAM verification is performed prior to entering into contract or covered transactions. Views of Responsible Officials and Planned Corrective Action: The Board of Education of the City of St. Louis recognizes the immediate need to update our Request for Proposal (RFP) template and include a Suspension and Debarment submission requirement as a part of our bidder checklist. Saint Louis Public Schools will create a procurement department procedure for checking the System for Award Management (SAM) to ensure potential vendors are in good standing with the Federal government before awarding Saint Louis Public Schools? contracts. Saint Louis Public Schools will generate and maintain SAM vendor record searches as evidence of procurement policy compliance.
Show full finding ▾Hide full finding ▴Federal Award Information: U.S. Department of Education, Special Education Cluster, passed through the Missouri Department of Elementary and Secondary Education CFDA No: 84.027 and 84.173 Federal Award ID: H027A170040, H027A180040, H173A180103 Compliance Requirement: Procurement and Suspension and Debarment Criteria: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into 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 from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition/Context: The District did not maintain documentation to support that suspension or debarment verification was performed prior to contracting or making covered transactions to entities. A certification or clause in the vendor contracts was also not required by the District. This deficiency was noted in the two covered transactions sampled out of the population of five. Statistical sampling method was not used. Both covered transactions were entered into with vendors who were not suspended or debarred. Questioned Costs: Undeterminable Cause: The District?s internal control over compliance did not operate effectively. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the samples selected. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Repeat Finding: No Recommendation: We recommend that the District adhere to their policy and maintain support that a SAM verification is performed prior to entering into contract or covered transactions. Views of Responsible Officials and Planned Corrective Action: The Board of Education of the City of St. Louis recognizes the immediate need to update our Request for Proposal (RFP) template and include a Suspension and Debarment submission requirement as a part of our bidder checklist. Saint Louis Public Schools will create a procurement department procedure for checking the System for Award Management (SAM) to ensure potential vendors are in good standing with the Federal government before awarding Saint Louis Public Schools? contracts. Saint Louis Public Schools will generate and maintain SAM vendor record searches as evidence of procurement policy compliance.
Personnel Responsible for Corrective Action: Procurement Director Anticipated Completion Date: January 1, 2020 Corrective Action Plan: The Board of Education of the City of St. Louis recognizes the immediate need to update our Request for Proposal (RFP) template and include a Suspension and Debarment submission requirement as a part of our bidder checklist. Saint Louis Public Schools will create a procurement department procedure for checking the System for Award Management (SAM) to ensure potential vendors are in good standing with the Federal government before awarding Saint Louis Public Schools? contracts. Saint Louis Public Schools will generate and maintain SAM vendor record searches as evidence of procurement policy compliance.
FAC accepted this audit on January 2, 2019 — management decision was due July 2, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on January 2, 2018 — management decision was due July 2, 2018.
FAC accepted this audit on January 10, 2017 — management decision was due July 10, 2017.
GSA_MIGRATION
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