Criteria: Contracts and subcontracts involving construction activity with federal funds are subject to
the Davis-Bacon prevailing wage requirements. As such, the School Board, as a
subgrantee to the State of LA, must monitor its construction contractors through review of
payrolls for payment of Davis Bacon Act prevailing wage requirements.
Condition: The School Board conducted construction activities with the ESSER funds, including
roofing, window replacements, and other, but did not monitor its contractors’ compliance
with Davis Bacon wage requirements.
Universe/
Population: Approximately $345,000 was spent on construction type activities that under projects that
would have required monitoring. None of the contractors performing the activity were
monitored.
Effect: The School Board is non-compliant with the requirements to monitor its subrecipients with
respect to Davis-Bacon compliance.
Cause: Construction activities are rarely conducted with educationally related federal grants and
the administration was unfamiliar with the requirements.
Recommendation: The School Board should be wary of all grant requirements prior to acceptance of the grant
award.
View of Responsible Officials and Corrective Action Plan:
The Federal Programs Director acknowledges that we were not compliant with
the Davis-Bacon requirement concerning prevailing wages. This project was
completed early in the process of receiving ESSER funding and we were unaware
of the Davis-Bacon wage requirements. Moving forward, the Federal Programs
department and the Business department will work together to ensure that all
Davis-Bacon requirements are met.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections
200.318 through 200.326 (the Uniform Guidance) and use their own documented
procurement procedures, which reflect applicable State and local laws and regulations
provided that the procurements conform to applicable Federal statutes and the procurement
requirements identified in 2 CFR part 200. Internal controls should be designed to ensure
compliance with these federal requirements.Additionally, contracts involving federal funds
must include certain provisions of Appendix II part 200.
Condition: The Child Nutrition Program is administered for the School Board by the CNP department.
The Department’s purchase of produce products was not subjected to bidding or other
means of competitive solicitation in accordance with the Unform Guidance. Additionally,
the contracts with vendors do not include the provisions contained in Appendix II part 200.
Universe/
Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000,
among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4
audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be
non-compliant.
Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this
contract for produce products.
Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the
pricing and/or bidding process.
Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be
conducted by the School Board’s Child Nutrition Department. Contracts should be
standardized to include the language and provisions of Appendix II part 200.
View of Responsible Official and Corrective Action Plan:
The Child Nutrition Supervisor acknowledges the finding regarding the purchase of
produce products for SY 2022-23. There is only one regional produce distributor that
successfully delivers to the Franklin Parish area with accurate invoices and timely
deliveries based on past history. Due to staff changes and re-assignment of essential
job functions, the produce bid was overlooked for this this year only. Moving forward,
the CNP Supervisor bas established a procurement schedule for developing and
revising necessary formal bids in compliance with Federal and State requirements and
all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition
Program experienced multiple shortages of canned and frozen vegetables and fruits.
This made it essential to fill in with fresh produce to meet meal pattern requirements.
This created a marked increase in the cost of the fresh produce available to us and
increased our reliance on fresh produce.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections
200.318 through 200.326 (the Uniform Guidance) and use their own documented
procurement procedures, which reflect applicable State and local laws and regulations
provided that the procurements conform to applicable Federal statutes and the procurement
requirements identified in 2 CFR part 200. Internal controls should be designed to ensure
compliance with these federal requirements.Additionally, contracts involving federal funds
must include certain provisions of Appendix II part 200.
Condition: The Child Nutrition Program is administered for the School Board by the CNP department.
The Department’s purchase of produce products was not subjected to bidding or other
means of competitive solicitation in accordance with the Unform Guidance. Additionally,
the contracts with vendors do not include the provisions contained in Appendix II part 200.
Universe/
Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000,
among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4
audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be
non-compliant.
Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this
contract for produce products.
Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the
pricing and/or bidding process.
Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be
conducted by the School Board’s Child Nutrition Department. Contracts should be
standardized to include the language and provisions of Appendix II part 200.
View of Responsible Official and Corrective Action Plan:
The Child Nutrition Supervisor acknowledges the finding regarding the purchase of
produce products for SY 2022-23. There is only one regional produce distributor that
successfully delivers to the Franklin Parish area with accurate invoices and timely
deliveries based on past history. Due to staff changes and re-assignment of essential
job functions, the produce bid was overlooked for this this year only. Moving forward,
the CNP Supervisor bas established a procurement schedule for developing and
revising necessary formal bids in compliance with Federal and State requirements and
all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition
Program experienced multiple shortages of canned and frozen vegetables and fruits.
This made it essential to fill in with fresh produce to meet meal pattern requirements.
This created a marked increase in the cost of the fresh produce available to us and
increased our reliance on fresh produce.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections
200.318 through 200.326 (the Uniform Guidance) and use their own documented
procurement procedures, which reflect applicable State and local laws and regulations
provided that the procurements conform to applicable Federal statutes and the procurement
requirements identified in 2 CFR part 200. Internal controls should be designed to ensure
compliance with these federal requirements.Additionally, contracts involving federal funds
must include certain provisions of Appendix II part 200.
Condition: The Child Nutrition Program is administered for the School Board by the CNP department.
The Department’s purchase of produce products was not subjected to bidding or other
means of competitive solicitation in accordance with the Unform Guidance. Additionally,
the contracts with vendors do not include the provisions contained in Appendix II part 200.
Universe/
Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000,
among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4
audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be
non-compliant.
Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this
contract for produce products.
Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the
pricing and/or bidding process.
Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be
conducted by the School Board’s Child Nutrition Department. Contracts should be
standardized to include the language and provisions of Appendix II part 200.
View of Responsible Official and Corrective Action Plan:
The Child Nutrition Supervisor acknowledges the finding regarding the purchase of
produce products for SY 2022-23. There is only one regional produce distributor that
successfully delivers to the Franklin Parish area with accurate invoices and timely
deliveries based on past history. Due to staff changes and re-assignment of essential
job functions, the produce bid was overlooked for this this year only. Moving forward,
the CNP Supervisor bas established a procurement schedule for developing and
revising necessary formal bids in compliance with Federal and State requirements and
all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition
Program experienced multiple shortages of canned and frozen vegetables and fruits.
This made it essential to fill in with fresh produce to meet meal pattern requirements.
This created a marked increase in the cost of the fresh produce available to us and
increased our reliance on fresh produce.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections
200.318 through 200.326 (the Uniform Guidance) and use their own documented
procurement procedures, which reflect applicable State and local laws and regulations
provided that the procurements conform to applicable Federal statutes and the procurement
requirements identified in 2 CFR part 200. Internal controls should be designed to ensure
compliance with these federal requirements.Additionally, contracts involving federal funds
must include certain provisions of Appendix II part 200.
Condition: The Child Nutrition Program is administered for the School Board by the CNP department.
The Department’s purchase of produce products was not subjected to bidding or other
means of competitive solicitation in accordance with the Unform Guidance. Additionally,
the contracts with vendors do not include the provisions contained in Appendix II part 200.
Universe/
Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000,
among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4
audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be
non-compliant.
Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this
contract for produce products.
Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the
pricing and/or bidding process.
Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be
conducted by the School Board’s Child Nutrition Department. Contracts should be
standardized to include the language and provisions of Appendix II part 200.
View of Responsible Official and Corrective Action Plan:
The Child Nutrition Supervisor acknowledges the finding regarding the purchase of
produce products for SY 2022-23. There is only one regional produce distributor that
successfully delivers to the Franklin Parish area with accurate invoices and timely
deliveries based on past history. Due to staff changes and re-assignment of essential
job functions, the produce bid was overlooked for this this year only. Moving forward,
the CNP Supervisor bas established a procurement schedule for developing and
revising necessary formal bids in compliance with Federal and State requirements and
all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition
Program experienced multiple shortages of canned and frozen vegetables and fruits.
This made it essential to fill in with fresh produce to meet meal pattern requirements.
This created a marked increase in the cost of the fresh produce available to us and
increased our reliance on fresh produce.
Criteria: Contracts and subcontracts involving construction activity with federal funds are subject to
the Davis-Bacon prevailing wage requirements. As such, the School Board, as a
subgrantee to the State of LA, must monitor its construction contractors through review of
payrolls for payment of Davis Bacon Act prevailing wage requirements.
Condition: The School Board conducted construction activities with the ESSER funds, including
roofing, window replacements, and other, but did not monitor its contractors’ compliance
with Davis Bacon wage requirements.
Universe/
Population: Approximately $345,000 was spent on construction type activities that under projects that
would have required monitoring. None of the contractors performing the activity were
monitored.
Effect: The School Board is non-compliant with the requirements to monitor its subrecipients with
respect to Davis-Bacon compliance.
Cause: Construction activities are rarely conducted with educationally related federal grants and
the administration was unfamiliar with the requirements.
Recommendation: The School Board should be wary of all grant requirements prior to acceptance of the grant
award.
View of Responsible Officials and Corrective Action Plan:
The Federal Programs Director acknowledges that we were not compliant with
the Davis-Bacon requirement concerning prevailing wages. This project was
completed early in the process of receiving ESSER funding and we were unaware
of the Davis-Bacon wage requirements. Moving forward, the Federal Programs
department and the Business department will work together to ensure that all
Davis-Bacon requirements are met.
Criteria: Contracts and subcontracts involving construction activity with federal funds are subject to
the Davis-Bacon prevailing wage requirements. As such, the School Board, as a
subgrantee to the State of LA, must monitor its construction contractors through review of
payrolls for payment of Davis Bacon Act prevailing wage requirements.
Condition: The School Board conducted construction activities with the ESSER funds, including
roofing, window replacements, and other, but did not monitor its contractors’ compliance
with Davis Bacon wage requirements.
Universe/
Population: Approximately $345,000 was spent on construction type activities that under projects that
would have required monitoring. None of the contractors performing the activity were
monitored.
Effect: The School Board is non-compliant with the requirements to monitor its subrecipients with
respect to Davis-Bacon compliance.
Cause: Construction activities are rarely conducted with educationally related federal grants and
the administration was unfamiliar with the requirements.
Recommendation: The School Board should be wary of all grant requirements prior to acceptance of the grant
award.
View of Responsible Officials and Corrective Action Plan:
The Federal Programs Director acknowledges that we were not compliant with
the Davis-Bacon requirement concerning prevailing wages. This project was
completed early in the process of receiving ESSER funding and we were unaware
of the Davis-Bacon wage requirements. Moving forward, the Federal Programs
department and the Business department will work together to ensure that all
Davis-Bacon requirements are met.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections
200.318 through 200.326 (the Uniform Guidance) and use their own documented
procurement procedures, which reflect applicable State and local laws and regulations
provided that the procurements conform to applicable Federal statutes and the procurement
requirements identified in 2 CFR part 200. Internal controls should be designed to ensure
compliance with these federal requirements.Additionally, contracts involving federal funds
must include certain provisions of Appendix II part 200.
Condition: The Child Nutrition Program is administered for the School Board by the CNP department.
The Department’s purchase of produce products was not subjected to bidding or other
means of competitive solicitation in accordance with the Unform Guidance. Additionally,
the contracts with vendors do not include the provisions contained in Appendix II part 200.
Universe/
Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000,
among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4
audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be
non-compliant.
Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this
contract for produce products.
Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the
pricing and/or bidding process.
Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be
conducted by the School Board’s Child Nutrition Department. Contracts should be
standardized to include the language and provisions of Appendix II part 200.
View of Responsible Official and Corrective Action Plan:
The Child Nutrition Supervisor acknowledges the finding regarding the purchase of
produce products for SY 2022-23. There is only one regional produce distributor that
successfully delivers to the Franklin Parish area with accurate invoices and timely
deliveries based on past history. Due to staff changes and re-assignment of essential
job functions, the produce bid was overlooked for this this year only. Moving forward,
the CNP Supervisor bas established a procurement schedule for developing and
revising necessary formal bids in compliance with Federal and State requirements and
all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition
Program experienced multiple shortages of canned and frozen vegetables and fruits.
This made it essential to fill in with fresh produce to meet meal pattern requirements.
This created a marked increase in the cost of the fresh produce available to us and
increased our reliance on fresh produce.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections
200.318 through 200.326 (the Uniform Guidance) and use their own documented
procurement procedures, which reflect applicable State and local laws and regulations
provided that the procurements conform to applicable Federal statutes and the procurement
requirements identified in 2 CFR part 200. Internal controls should be designed to ensure
compliance with these federal requirements.Additionally, contracts involving federal funds
must include certain provisions of Appendix II part 200.
Condition: The Child Nutrition Program is administered for the School Board by the CNP department.
The Department’s purchase of produce products was not subjected to bidding or other
means of competitive solicitation in accordance with the Unform Guidance. Additionally,
the contracts with vendors do not include the provisions contained in Appendix II part 200.
Universe/
Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000,
among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4
audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be
non-compliant.
Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this
contract for produce products.
Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the
pricing and/or bidding process.
Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be
conducted by the School Board’s Child Nutrition Department. Contracts should be
standardized to include the language and provisions of Appendix II part 200.
View of Responsible Official and Corrective Action Plan:
The Child Nutrition Supervisor acknowledges the finding regarding the purchase of
produce products for SY 2022-23. There is only one regional produce distributor that
successfully delivers to the Franklin Parish area with accurate invoices and timely
deliveries based on past history. Due to staff changes and re-assignment of essential
job functions, the produce bid was overlooked for this this year only. Moving forward,
the CNP Supervisor bas established a procurement schedule for developing and
revising necessary formal bids in compliance with Federal and State requirements and
all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition
Program experienced multiple shortages of canned and frozen vegetables and fruits.
This made it essential to fill in with fresh produce to meet meal pattern requirements.
This created a marked increase in the cost of the fresh produce available to us and
increased our reliance on fresh produce.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections
200.318 through 200.326 (the Uniform Guidance) and use their own documented
procurement procedures, which reflect applicable State and local laws and regulations
provided that the procurements conform to applicable Federal statutes and the procurement
requirements identified in 2 CFR part 200. Internal controls should be designed to ensure
compliance with these federal requirements.Additionally, contracts involving federal funds
must include certain provisions of Appendix II part 200.
Condition: The Child Nutrition Program is administered for the School Board by the CNP department.
The Department’s purchase of produce products was not subjected to bidding or other
means of competitive solicitation in accordance with the Unform Guidance. Additionally,
the contracts with vendors do not include the provisions contained in Appendix II part 200.
Universe/
Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000,
among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4
audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be
non-compliant.
Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this
contract for produce products.
Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the
pricing and/or bidding process.
Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be
conducted by the School Board’s Child Nutrition Department. Contracts should be
standardized to include the language and provisions of Appendix II part 200.
View of Responsible Official and Corrective Action Plan:
The Child Nutrition Supervisor acknowledges the finding regarding the purchase of
produce products for SY 2022-23. There is only one regional produce distributor that
successfully delivers to the Franklin Parish area with accurate invoices and timely
deliveries based on past history. Due to staff changes and re-assignment of essential
job functions, the produce bid was overlooked for this this year only. Moving forward,
the CNP Supervisor bas established a procurement schedule for developing and
revising necessary formal bids in compliance with Federal and State requirements and
all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition
Program experienced multiple shortages of canned and frozen vegetables and fruits.
This made it essential to fill in with fresh produce to meet meal pattern requirements.
This created a marked increase in the cost of the fresh produce available to us and
increased our reliance on fresh produce.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections
200.318 through 200.326 (the Uniform Guidance) and use their own documented
procurement procedures, which reflect applicable State and local laws and regulations
provided that the procurements conform to applicable Federal statutes and the procurement
requirements identified in 2 CFR part 200. Internal controls should be designed to ensure
compliance with these federal requirements.Additionally, contracts involving federal funds
must include certain provisions of Appendix II part 200.
Condition: The Child Nutrition Program is administered for the School Board by the CNP department.
The Department’s purchase of produce products was not subjected to bidding or other
means of competitive solicitation in accordance with the Unform Guidance. Additionally,
the contracts with vendors do not include the provisions contained in Appendix II part 200.
Universe/
Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000,
among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4
audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be
non-compliant.
Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this
contract for produce products.
Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the
pricing and/or bidding process.
Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be
conducted by the School Board’s Child Nutrition Department. Contracts should be
standardized to include the language and provisions of Appendix II part 200.
View of Responsible Official and Corrective Action Plan:
The Child Nutrition Supervisor acknowledges the finding regarding the purchase of
produce products for SY 2022-23. There is only one regional produce distributor that
successfully delivers to the Franklin Parish area with accurate invoices and timely
deliveries based on past history. Due to staff changes and re-assignment of essential
job functions, the produce bid was overlooked for this this year only. Moving forward,
the CNP Supervisor bas established a procurement schedule for developing and
revising necessary formal bids in compliance with Federal and State requirements and
all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition
Program experienced multiple shortages of canned and frozen vegetables and fruits.
This made it essential to fill in with fresh produce to meet meal pattern requirements.
This created a marked increase in the cost of the fresh produce available to us and
increased our reliance on fresh produce.
Criteria: Contracts and subcontracts involving construction activity with federal funds are subject to
the Davis-Bacon prevailing wage requirements. As such, the School Board, as a
subgrantee to the State of LA, must monitor its construction contractors through review of
payrolls for payment of Davis Bacon Act prevailing wage requirements.
Condition: The School Board conducted construction activities with the ESSER funds, including
roofing, window replacements, and other, but did not monitor its contractors’ compliance
with Davis Bacon wage requirements.
Universe/
Population: Approximately $345,000 was spent on construction type activities that under projects that
would have required monitoring. None of the contractors performing the activity were
monitored.
Effect: The School Board is non-compliant with the requirements to monitor its subrecipients with
respect to Davis-Bacon compliance.
Cause: Construction activities are rarely conducted with educationally related federal grants and
the administration was unfamiliar with the requirements.
Recommendation: The School Board should be wary of all grant requirements prior to acceptance of the grant
award.
View of Responsible Officials and Corrective Action Plan:
The Federal Programs Director acknowledges that we were not compliant with
the Davis-Bacon requirement concerning prevailing wages. This project was
completed early in the process of receiving ESSER funding and we were unaware
of the Davis-Bacon wage requirements. Moving forward, the Federal Programs
department and the Business department will work together to ensure that all
Davis-Bacon requirements are met.