EIN: 836000633
UEI: JPUDH3CXB657
Audited by: CARVER FLOREK & JAMES, CPA'S
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 16, 2025. 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 June 16, 2026 (73 days ago).
What is a management decision? →2025-003: Procurement Procedures (Significant Deficiency and Noncompliance) Federal Program: IDEA Special Education Federal ALN: 84.027/84.173 Criteria: Under 2 CFR §200.318-§200.320, non-federal entities must conduct all procurement transactions in a manner providing full and open competition and must follow documented procurement procedures consistent with federal standards. Additionally, 2 CFR §200.214 (previously §200.213) requires non-federal entities to verify that contractors are not suspended or debarred from doing business with the federal government. This verification may be accomplished by checking the System for Award Management (SAM.gov) or obtaining a certification from the vendor. Condition and Context: During our testing of procurement transactions, we identified two (2) contracts in which bids were not solicited as required by the District's procurement policy and Uniform Guidance. In addition, suspension and debarment checks were not performed or documented for these vendors prior to contract award. Cause: The exceptions occurred because procurement procedures were not consistently followed, and management did not perform or document required suspension/debarment verifications prior to contract execution. This may have been due to oversight or lack of staff training regarding Uniform Guidance procurement requirements. Effect or Potential Effect: Failure to solicit bids and perform suspension/debarment checks increases the risk of noncompliance with federal regulations, potential ineligible costs charged to federal programs, and diminished assurance that contracts are awarded fairly and to responsible parties. Questioned Costs: None. Identification as a Repeat Finding: No. Recommendation: We recommend that management strengthen procurement procedures to ensure compliance with Uniform Guidance requirements. Specifically: - Solicit bids or proposals in accordance with applicable competitive procurement thresholds; - Perform and document suspension and debarment checks (e.g., through SAM.gov) prior to awarding contracts; and - Provide staff training on federal procurement standards and maintain documentation supporting compliance for each federally funded procurement. Responsible Official's Response: Please see the last page of this report for the response to this finding.
Show full finding ▾Hide full finding ▴2025-003: Procurement Procedures (Significant Deficiency and Noncompliance) Federal Program: IDEA Special Education Federal ALN: 84.027/84.173 Criteria: Under 2 CFR §200.318-§200.320, non-federal entities must conduct all procurement transactions in a manner providing full and open competition and must follow documented procurement procedures consistent with federal standards. Additionally, 2 CFR §200.214 (previously §200.213) requires non-federal entities to verify that contractors are not suspended or debarred from doing business with the federal government. This verification may be accomplished by checking the System for Award Management (SAM.gov) or obtaining a certification from the vendor. Condition and Context: During our testing of procurement transactions, we identified two (2) contracts in which bids were not solicited as required by the District's procurement policy and Uniform Guidance. In addition, suspension and debarment checks were not performed or documented for these vendors prior to contract award. Cause: The exceptions occurred because procurement procedures were not consistently followed, and management did not perform or document required suspension/debarment verifications prior to contract execution. This may have been due to oversight or lack of staff training regarding Uniform Guidance procurement requirements. Effect or Potential Effect: Failure to solicit bids and perform suspension/debarment checks increases the risk of noncompliance with federal regulations, potential ineligible costs charged to federal programs, and diminished assurance that contracts are awarded fairly and to responsible parties. Questioned Costs: None. Identification as a Repeat Finding: No. Recommendation: We recommend that management strengthen procurement procedures to ensure compliance with Uniform Guidance requirements. Specifically: - Solicit bids or proposals in accordance with applicable competitive procurement thresholds; - Perform and document suspension and debarment checks (e.g., through SAM.gov) prior to awarding contracts; and - Provide staff training on federal procurement standards and maintain documentation supporting compliance for each federally funded procurement. Responsible Official's Response: Please see the last page of this report for the response to this finding.
Corrective Action Plan for Audit Finding 2025-003: Procurement Procedures (Significant Deficiency and Noncompliance - IDEA Special Education Federal Program) Finding Summary: Auditors identified two instances in which procurement transactions did not comply with the District's procurement policy or federal Uniform Guidance requirements. Specifically, bids were not solicited as required, and suspension and debarment checks were not performed or documented for the vendors prior to contract award. Root Cause: The exceptions occured due to a gap in the District's internal control structure. These procedures were not being consistently performed, and prior management was unaware the requirements under federal Uniform Guidance were not being followed. Corrective Action: The District will establish and implement policies and procedures to ensure all federally funded procurements comply with Uniform Guidance requirements. This includes: 1. Soliciting bids or proposals in accordance with applicable competitive procurement thresholds. 2. Performing and documenting suspension and debarment verifications for all vendors, including tracking results appropriately. 3. Providing training to staff responsible for federal procurement to ensure ongoing compliance and understanding of federal requirements. These actions are intended to ensure that contracts are awarded fairly, to responsible parties, and in full compliance with federal regulations. Documentation of all procurement steps will be maintained to demonstrate compliance during future audits. Responsible Parties: Fiona Barry, Assistant CFO, and Matthew Gonzales, CFO, are responsible for overseeing implementation, ensuring proper documentation, and providing staff training. Timeline: The corrective actions are scheduled for implementation by March 2026 and will continue as part of the District's ongoing procurement compliance process.
FAC accepted this audit on January 12, 2023 — management decision was due July 12, 2023.
Criteria or Specific Requirement Allowable Costs/Cost Principles ? Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition An employee that was hired to work in an allowable position subsequently accepted another position within the District. The District paid the employee from August 2021 through January 2022 charging the cost to the federal award. The unallowed charge was discovered when the employee was asked to complete the semi-annual certification. Cause When it was discovered, the District noted that a correction should be made to remove the payroll cost charged, but due to a breakdown in the internal controls, the correction was not made. District personnel failed to follow through on the required paperwork. Effect or Potential Effect The error resulted in an overstatement of revenue requested for the ESSER award. Expenditures of special revenue fund were overstatement and expenditures of general fund were understated. There was also a misstatement of the amounts due to/from other funds. Questioned Cost Salary and benefits charged to federal award $53,239. Identification as a Repeat Finding This a not a repeat finding. Recommendation The District should return the funds to the Wyoming Department of Education. The District needs to revisit internal control processes regarding verification of employees being charged to federal awards throughout the award period rather than just when requesting semi-annual certifications. The District needs to review the monitoring process to ensure that when an adjusting entries is noted as being required that follow through happens to complete the process, in a timely manner. View of Responsible Officials Please refer to the District?s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirement Allowable Costs/Cost Principles ? Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition An employee that was hired to work in an allowable position subsequently accepted another position within the District. The District paid the employee from August 2021 through January 2022 charging the cost to the federal award. The unallowed charge was discovered when the employee was asked to complete the semi-annual certification. Cause When it was discovered, the District noted that a correction should be made to remove the payroll cost charged, but due to a breakdown in the internal controls, the correction was not made. District personnel failed to follow through on the required paperwork. Effect or Potential Effect The error resulted in an overstatement of revenue requested for the ESSER award. Expenditures of special revenue fund were overstatement and expenditures of general fund were understated. There was also a misstatement of the amounts due to/from other funds. Questioned Cost Salary and benefits charged to federal award $53,239. Identification as a Repeat Finding This a not a repeat finding. Recommendation The District should return the funds to the Wyoming Department of Education. The District needs to revisit internal control processes regarding verification of employees being charged to federal awards throughout the award period rather than just when requesting semi-annual certifications. The District needs to review the monitoring process to ensure that when an adjusting entries is noted as being required that follow through happens to complete the process, in a timely manner. View of Responsible Officials Please refer to the District?s Corrective Action Plan.
On a monthly basis, the grant department will review the payroll register to verify the payroll is being charged correctly to the federal awards. The grant department staff will notify the Director of Grants and Federal Programs of any employees that are incorrectly charged to a grant. When an error is discovered, an adjusting journal entry will be prepared soon thereafter and reviewed by the Director of Grants and Federal Programs.
FAC accepted this audit on December 26, 2016 — management decision was due June 26, 2017.
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