Digital Pioneers Academy Public Charter School

Title V, Part B, Charter Schools: CFDA# 84.282 Criteria and Condition: In accordance with the procurement standards as promulgated in Section 200.318 of 2 CFR Chapter 1, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, an organization that receives federal funding is required to have a written procurement policy and procedures manual, which reflect applicable federal laws and required procurement procedures as identified in the Uniform Guidance. Digital Pioneers Academy Public Charter School has a written financial policies and procedures manual; however, it does not include some of the necessary requirements as they relate to federal standards and compliance. This manual has been written to address primarily the procurement procedures required by the charter school authorizer (DCPCSB). Included within this manual is a policy statement which states that the School will comply with procurement standards as required under the Uniform Administrative Requirements. Questioned Cost: $0 Context: The District of Columbia Public Charter School Board, the Charter School authorizing body, has developed a detailed and robust set of standards to be followed by Charter Schools within the District of Columbia. Although these standards cover many facets of the procurement process, they do not address the additional requirements as required by federal statutes. In addition, procurement procedures as issued from the District of Columbia Public Charter School Board also exempt certain services and items from the procurement standards that are not exempt under federal standards. Cause: The Charter School has a written procurement policy manual that corresponds to the procurement standards as promulgated by the District of Columbia Public Charter School Board, which primarily addresses those procedures necessary for nonexempt procurement actions greater than $25,000. The Charter School?s initial year of operations began on July 1, 2018, and management believed the procurement manual that had been adopted would satisfy the requirement of having a federal policy and procurement manual. Effect: Federal procurement standards have been established to ensure that all procurement actions are conducted in a manner to ensure, to the maximum extent practical, that the solicitation and award of a procurement transaction is most advantageous to both the federal government and the Charter School. By utilizing procurement standards that do not fully conform to federal standards, a contract could be awarded that would otherwise not be considered most advantageous to one or either party. Recommendation: We recommend that the current written financial policies and procedures manual be expanded to include the many additional provisions as required under the Uniform Guidance. This includes, but is not limited to, (1) micro-purchase procedures, (2) quotation and analysis processes between $10,000 and $250,000, (3) federal sole source provisions, (4) selection process, (5) contract provisions, and (6) procurement records. Views of Responsible Official: The Organization has modified its Financial Policies and Procedures to codify the Organization?s adherence to Uniform Grant Guidance for federally funded expenditures. The most notable additions to the policy are excerpted below: ?The Organization reviews the following websites: https://www.sam.gov and Excluded Parties List - OCP -DC to ensure that prospective vendors are not debarred or suspended. The School takes a screen snapshot of the page on the date of inquiry and saves the information electronically to ensure evidence of compliance with this requirement is readily available. For equipment purchased fully or partially by federally funded dollars, the Organization follows all regulations and requirements stated in 2 CFR 200.13 (or subsequent guidance). Any equipment purchased with federal funds must be used in the program/project in which it was acquired as long as it is needed. It will be used on other programs providing such use does not interfere with the work on the programs for which it was originally acquired. All equipment, whether or not it is purchased with federal funds, will be protected from loss, theft, and abuse. The Organization will ensure adequate measures are implemented and enforced, including but not limited to: maintaining and periodically reviewing inventory records, locking doors, and using technology security systems and software, as applicable.? And, ?In accordance with Uniform Grant Guidance, ? If purchase is less than $10,000, the Organization will verify that the purchase was reasonable, necessary, and that all practical efforts were made to distribute purchases equitably among qualified suppliers. ? If purchase is between $10,001 and $249,999, the Organization will review pricing/bids/quotes from at least three vendors, compare the costs of each, and store records of the review of the pricing/bids/quotes. ? If purchase is greater than $250,000, the Organization will solicit competitive proposals or sealed bids through a formal process in accordance with federal, state, and local requirements. ? If purchase is considered a Sole Source, the Organization shall store all records and analysis in support of that assessment. The Federal Grant Compliance Checklist guides DPA?s adherence to Uniform Grant Guidance. The Federal Grant Compliance Checklist is completed by anyone making a purchase of supplies, services, or travel that will be reimbursed with federal grant funds.?