EIN: 810329139
UEI: RZB2BQSH44F5
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 15, 2020. 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 October 15, 2020 (2137 days ago).
What is a management decision? →We obtained the Cooperative procurement policies and identified the suspension and debarment procedures to be followed for the remodel project paid with IDEA Part B funds. We noted, that the Cooperative did not advertise for bids as stated in the policy and as federal guidelines require for open and full competition. In addition, we noted the contract with the awarded vendor did not include suspension and debarment certifications or assurances.Criteria: 2 CFR section 200.318 states in part ?The non-Federal entity must follow its own documented procurement procedures which reflect application State, local and tribal laws and regulations, provided that the procurements conform to applicable Federal law and standards identified in this part.? The Cooperative policy 7320 Purchasing states in part ?Whenever any building furnishing, repairing, or other work for the benefit of the Cooperative or purchasing of supplies for the Cooperative is necessary, the work done or the purchase made must be by contract if the sum exceeds Fifty Thousand Dollars ($50,000). The Cooperative will call for formal bids by issuing public notice as specified in statute. Specifications will be prepared and made available to all vendors interested in submitting a bid.? and ?Advertisement for bid must be made once each week for two (2) consecutive weeks, and a second (2nd) publication must be made not less than five (5) nor more than twelve (12) days before consideration of bids.? In addition, 2 CFR section 200.319 state in part ?All procurement transactions must be conducted in manner providing full and open competition consistent with the standards of this section.? Finally, the Cooperative indicated certifications are required and the contracts would state a clause or condition in relation to suspension and debarment. Context: We tested the internal controls and compliance with procurement, suspension and debarment in relation to the IDEA Part B funds used to remodel the building purchased. Effect: The Cooperative did not have adequate controls regarding procurement, suspension and debarment. In addition, the Cooperative was not in compliance with the procurement rules requiring full and open competition. Cause: The Cooperative did not follow the purchasing procedures and did not have procedures documented for suspension and debarment. Recommendation: The Cooperative should review the purchasing procedures established to ensure the procedures meet the federal guidelines when procuring goods or services with federal funds. In addition, the procedures established should be followed in all cases. Finally, the Cooperative should established suspension and debarment policies and procedures.
Show full finding ▾Hide full finding ▴2019-002 Procurement, Suspension and Debarment CFDA Title: Special Education Grants to States CFDA Number: 84.027 Federal Award Number: 01596957719 Federal Agency: U.S. Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: We obtained the Cooperative procurement policies and identified the suspension and debarment procedures to be followed for the remodel project paid with IDEA Part B funds. We noted, that the Cooperative did not advertise for bids as stated in the policy and as federal guidelines require for open and full competition. In addition, we noted the contract with the awarded vendor did not include suspension and debarment certifications or assurances.Criteria: 2 CFR section 200.318 states in part ?The non-Federal entity must follow its own documented procurement procedures which reflect application State, local and tribal laws and regulations, provided that the procurements conform to applicable Federal law and standards identified in this part.? The Cooperative policy 7320 Purchasing states in part ?Whenever any building furnishing, repairing, or other work for the benefit of the Cooperative or purchasing of supplies for the Cooperative is necessary, the work done or the purchase made must be by contract if the sum exceeds Fifty Thousand Dollars ($50,000). The Cooperative will call for formal bids by issuing public notice as specified in statute. Specifications will be prepared and made available to all vendors interested in submitting a bid.? and ?Advertisement for bid must be made once each week for two (2) consecutive weeks, and a second (2nd) publication must be made not less than five (5) nor more than twelve (12) days before consideration of bids.? In addition, 2 CFR section 200.319 state in part ?All procurement transactions must be conducted in manner providing full and open competition consistent with the standards of this section.? Finally, the Cooperative indicated certifications are required and the contracts would state a clause or condition in relation to suspension and debarment. Context: We tested the internal controls and compliance with procurement, suspension and debarment in relation to the IDEA Part B funds used to remodel the building purchased. Effect: The Cooperative did not have adequate controls regarding procurement, suspension and debarment. In addition, the Cooperative was not in compliance with the procurement rules requiring full and open competition. Cause: The Cooperative did not follow the purchasing procedures and did not have procedures documented for suspension and debarment. Recommendation: The Cooperative should review the purchasing procedures established to ensure the procedures meet the federal guidelines when procuring goods or services with federal funds. In addition, the procedures established should be followed in all cases. Finally, the Cooperative should established suspension and debarment policies and procedures.
FINDING 2019-002: Procurements, Suspension and Debarment Contact Person: Cheryl Russell, Flathead Special Education Director Expected Completion Date of Corrective Action Plan: A complete corrective plan was completed through the recommended review of policies that was made after an email statement was sent to FSEC on January 13, 2020. A full demonstration of correction action will be made by March 30, 2020 as advertisement for bids will be marketed in local newspapers following the public notice as specified in statue for the second phase (exterior) of the Cooperative building. This will be followed by a procedural statement put in to the accepting contract that all certifications will be subject to a search for assurance regarding Suspensions and disbarments. CORRECTIVE ACTION PLAN As recommended a review of the Cooperative purchasing procedures and Procurement was completed upon the date of the findings on January 13, 2020 and January 14, 2020. As recommended a procedure for Suspension and Disbarment demonstrating certifications and or assurances are in place. A greater understanding of the Cooperative policy has since been made by this Director. In regards to suspension and debarment, The Cooperative will indicate that all certifications are required and the contracts would state a clause or condition in relation to suspension and debarment. Response: With a humble heart I greatly apologize for my lack of understanding in this area. Although, I take full responsibility and understand my lack of knowledge in this area brought forth by this finding I appreciate the opportunity to explain why Procurements, Suspension & Debarment were not followed correctly. I was hired as the Director of Flathead Special Education Cooperative (FSEC) in March of 2018 when I visited the Co-op at that time, I was told there would be a brand new building adjacent to the existing building when I took over as director on July 1, 2018 for our Special Education Preschool Program. However, upon arriving to the Co-op in July there was no preschool building, not even any excavation or construction of any kind had taken place. We had a 1970 square ft building that was used for a conference room three office areas and one classroom with an existing 4 students. By the end of August our existing building would need to be set up for an additional 15 potential preschoolers and 4 additional staff. We converted the Conference room into a preschool classroom to meet this need as best we could within our limited space and time constraints. We also began examining why our new building hadn?t been started yet and found out there were issues with permits due to a variety of findings and greatly increased cost factors. However, through this process we were able to ascertain that we would not have enough funds to complete the building project. Upon further review we realized that the space would also be too small for our current numbers and there was not sufficient parking on our lots for all staff. The decision to stop the plans on the new construction build and examine other viable options to meet our Preschool, Communication programs and Related Staff needs was recommended by Cheryl Russel, Director and agreed upon by our Management Board. We had approximately 24 itinerant FSEC employees and no meeting place available in our existing building. The then current Contractor, Mountain Eagle Construction was unable to support our project when it would no longer be a new construction build and said we would need to find someone else. It is at this point that I now know I should have followed the federal guidelines and Cooperative policy and not the guidelines that were in place in the file. Due to the necessity of funds and time limits we decided it was in the best interest of the Co-op and our student programs to locate a building that would need to be remodeled because that would afford us the opportunity to gain square footage. We were able to sell our vacant lot and free up enough funds to buy a building on 305 3rd Av E, Kalispell MT 59901with a total of 5700 square feet and structurally already ADA. I followed guidance in the previous file applying them to our new direction and did not realize the procurement error that this caused. I am deeply sorry for that error. As a person who had worked for Kalispell District 5 for 22 years, I had knowledge of contractors who completed school construction in our area as well as our Management Board because they are a group of Principals in our local area who have also had construction occurring in their buildings. I shared these names with our Management Board and they thought they were great folks to contact. I was able to contact Swank, Ross & Meredith and asked if they could come and give us an estimate on the building that we were able to purchase. Swank responded that they were too busy with Kalispell District 5 to be able to look at smaller remodels, Meredith did not respond at all and Ross responded with a yes and completed an estimate for us. I was able to share with the Management Board that we had only heard back from Ross and asked if I could contact Finnish-Finish and the Vandalay Group out of Whitefish as they completed smaller projects. The Vandalay Group did not want to do a remodel at that time. Finnish Finish responded with a yes and completed an estimate for us. Out of those estimates (Ross & Finnish-Finish) Finnish-Finish had addressed all the findings that were completed by Pillar to Post (structural assessment and home inspection) and Kirby Environmental who had completed a full inspection for hazard materials. (mold, asbestos, etc) on all interior, exterior and components associated with the building) with a very detailed list.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and compliance status.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.