Claremont Learning PartnershipNon-Profit

Criteria: The acquisition of property or services which is higher than the micro-purchase threshold ($10,000 at the time of the grant in question) but does not exceed the simplified acquisition threshold ($250,000 established in the FAR) must follow small purchase procedures. Small purchase procedures include price or rate quotations obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Additionally, the non-Federal entity may select noncompetitive procurement as their procurement method but must meet one of the five mentioned circumstances in 2 CFR 200.320(c). Lastly, general procurement standards must be followed. Questioned Costs: None. Repeat finding: The same finding was reported during the program specific audit as of and for the year ended December 31, 2022 as 2022-001. Recommendation: We recommend that the Organization adopt a procurement procedure in compliance with 2 CFR and ensure they have a full understanding of the required procurement policy. Views of Responsible Officials: A procurement procedure has since been adopted and approved by the Board. The Executive Director will ensure that all future purchases comply with 2 CFR. Condition: During our audit, certain grant expenditures with subcontractors, exceeding $10,000, were tested for which the Organization did not obtain quotes for. Cause: The Organization did not obtain quotes from subcontractors that were included in a contractor’s original bid. The Organization ultimately paid the subcontractors directly. Effect: The Organization did not adequately comply with 2 CFR 200.320. Non-compliance could lead to additional compliance concerns and questioned costs.

Criteria: The Organization must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that they are managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: New Hampshire Department of Education (NHED) identified certain policies in its federal fiscal monitoring report dated November 28, 2023 that either needed updating or needed to be created. During our own audit procedures for the year ended December 31, 2023, we too noted certain of these policies lacking. Cause: The Organization does not have a dedicated accounting or grant management personnel. Effect: The Organization did not adequately establish and maintain effective internal controls. The lack of internal controls is non-compliant with 2 CFR 200.303, which could lead to additional compliance concerns and questioned costs. Questioned Costs: None Repeat finding: The same finding was reported during the program specific audit as of and for the year ended December 31, 2022 as 2022-002. Recommendation: We recommend updating policies and procedures to include the requirements of Federal rules and laws for those transactions or activities that include Federal grant funds. As per NHED’s federal fiscal monitoring report, at a minimum, the following policies and procedures need to be created, updated, and/or implemented by the school: 1. Procurement Policy in accordance with updated 2 CFR 200.317-327. 2. Procurement Procedure in accordance with 2 CFR 200.317-327. 3. Time and Effort Procedure in accordance with 2 CFR 200.431. 4. Drug Free Workplace Policy in accordance with 34 CFR 84.200 and Drug Free Workplace Act of 1988 5. Inventory Management Procedure in accordance with 2 CFR 200.313(d) Views of Responsible Officials: All policies and procedures have since been vetted by an attorney and approved by the Board. The Executive Director will ensure that all policies and procedures stay current and are reviewed by the Board annually.