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Single Audit Update 2006 WASBO Conference

Single Audit Update 2006 WASBO Conference. Presented by: JoLynn Berge, OSPI Brad White, SAO. Overview. Today, we plan to discuss: Regulations over procurements made with federal funds. Complying with Suspension and Debarment rules related to your procurements. New CPR monitoring process.

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Single Audit Update 2006 WASBO Conference

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  1. Single Audit Update2006 WASBO Conference Presented by: JoLynn Berge, OSPI Brad White, SAO

  2. Overview Today, we plan to discuss: • Regulations over procurements made with federal funds. • Complying with Suspension and Debarment rules related to your procurements. • New CPR monitoring process. • Areas of federal focus.

  3. Procurement Suspension and Debarment • Districts must procure contracts for goods and services in accordance with state law and the A-102 Common Rule. • Districts must ensure that vendors and subrecipients are not suspended or debarred from participating in federal programs. • The auditor will evaluate your internal controls over these areas and determine if you have complied.

  4. From the OSPI Accounting Manual: • “Districts will use their own procurement procedures (purchasing processes) that include applicable state and local laws and regulations provided they conform to federal laws and standards. When purchasing supplies and equipment, competitive procurement practices must be used.” • This policy is also found in USDA regulations at 7 CFR 3016.36(b) and 7 CFR 3015.182 and Dept of Education at 34 CFR 80.36(b).

  5. State Laws for Purchases of Furniture, Equipment or Supplies, Except Books Thresholds for procurement methods: Pre 7-24-2005As of 7-24-2005 Competitive Basis $15,000 $40,000 Formal Bid $50,000 $75,000

  6. State Laws for Purchases of Furniture, Equipment or Supplies, Except Books • Competitive Basis = quotes from at least 3 sources obtained in writing or by telephone and recorded for public perusal. • Formal Bid = Notice of complete plans and specifications advertised in at least one newspaper of general circulation once each week for two consecutive weeks of the intent to receive bids. Bids shall be in writing and opened and read in public on the date and place named in the notice. Bids shall be open for public inspection.

  7. Circular A-102 Common Rule • If the type of item being procured is not covered under state law (e.g., professional services), you default to the A-102 Common Rule (34 CFR 80.36). • A-102 requires quotes from an adequate number of vendors for purchases up to $100,000. • Bidding or Competitive Negotiation required for procurements over $100,000. Sole-source designation is an option.

  8. Suspension and Debarment For any vendor contracts over $25,000 and all subrecipients, a district must perform one of the following: • Check the Excluded Parties List System (EPLS) at http://www.epls.gov/ or subscribe to the hard copy; (BE SURE TO PRINT OUT YOUR SEARCH) • Collect a certification from that person; or • Add a clause or condition to the coveredtransaction with that person.

  9. Suspension and Debarment In addition to checking the status of your lower tier party (e.g., contractor or subrecipient), you must also inform the lower tier party that they must ensure that any of their covered transactions meet these rules and that they must communicate these rules to the next lower tier.

  10. Suspension and Debarment Grantor Grantee Subrecipient Vendor > $25,000 Sub Vendor $25K Vendor $25K

  11. Suspension and Debarment Where to find the regulations: USDA: 7 CFR 3017.300 ED: 34 CFR 85.300 HHS: 45 CFR 76.300

  12. New CPR Monitoring Process • Transitioning to a risk based approach. • Overarching fiscal issues. • Overarching programmatic issues. • Program specific issues.

  13. Who would be monitored? • Districts identified as “high risk” using some type of point system. • 4 yr. ESD cycle would continue and some districts would be chosen based on ESD region.

  14. What are overarching fiscal issues? • Audit results – SAO audits and CPR monitoring reports. • Volume – size of grant award, number of grants, new grants. • Student Performance Measures – grad rate, dropout rate, AYP/Report Card data, School Improvement status. • Financial Health/Grant Administration – fund balance, budgeting receivables, lapsed funds, application timelines, End-of-Year reports.

  15. Areas of Federal Focus • Subrecipient monitoring • Comparability • Participation of Private Schools • Equipment and inventory control

  16. Questions Do you have any other questions we have not answered?

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