POTOMAC SCHOOL DISTRICT #11Local Government

Federal Agency: U.S. Department of Education Federal Program: Comprehensive Literacy Development CFDA #: 84.371C Pass-through Entity: Montana Office of Public Instruction Criteria: Under Title 2 U.S. Code of Federal Regulations Part 180.300, when the District enters into a covered transaction, they must verify the parties they contract with are not excluded or disqualified. This can be done by checking a federal database for exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The District entered into two covered transaction during fiscal year 2021 for the Comprehensive Literacy Development program. The District did not have documentation that they checked the federal database for exclusions or a certification from the vendor. Cause: A policy regarding federal procurement requirements was adopted during fiscal year 2021, but procedures related to this policy were not fully implemented during the year under audit. Effect: The vendors in the covered transaction were not suspended or debarred, therefore no noncompliance resulted from the lack of procedures. Context: The District had only two covered transactions for this program, which were both tested. These transactions were with well-known vendors for commercially available products. Repeat Finding: No. Recommendations: Procedures related to the federal procurement policy should be reviewed to ensure adequate documentation is maintained to demonstrate compliance with suspension and debarment requirements. Views of Responsible Officials: The District acknowledges and understands this finding. Action has been taken in fiscal year 2022 to correct this. A certification form is in use, and the federal database is checked for exclusions.