U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-003 ? Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Conditions: During the 2021/2022 school year, several food service locations used paper tally sheets to document meals and snacks served to students. These tally sheets were compiled and used to submit the monthly requests for food service reimbursements under the federal grant program. During the audit, we noted instances of count sheets that had errors in the accumulation of totals, and certain other discrepancies. Management explained, and we observed that there were not review procedures in place surrounding the reporting process to the State of Michigan of lunch, breakfast, and snack student tally sheets. Criteria: Segregation of duties is key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction from beginning to end. Cause/Context: Manual tally sheets were only used at locations that did not utilize the electronic system implemented elsewhere in the school system. Since the process outside of the electronic system is entirely manual, it is susceptible to human error. The errors detected during our audit were not material individually, and not material when projected to the population. However, without a review process in place, errors are likely to go undetected. Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-004 ? Compliance Finding - Procurement Conditions and Criteria: Three transactions were selected for testing that exceeded the threshold for small purchases defined by procurement standards in 2 CFR 200.320(a). Specifically, the transactions were above the micro-purchase threshold (currently $10,000) but below the simplified acquisition threshold (currently $250,000), and the transactions qualified as small purchases. The regulations in 2 CFR 200(a)(2) require price or rate quotations be obtained from an adequate number of qualified sources. Cause: The Schools does not currently have a procurement policy that contains the requirements outlined in the regulations defined above. Context: The transactions relevant to this finding are associated with the renovation of the middle school kitchen and the purchase of related food service and kitchen equipment that exceeded the micro purchases threshold. These transactions individually qualify as small purchases (under $250,000) and require at least competitive pricing or quotes. The transactions tested total approximately $353,500, and represent the population of purchases that met this threshold during the year. Competitive quotes were not solicited. Rather, GRCS contracted with the providers recommended by management. Management explained that the contractor selected for construction previously renovated the school, and understood the scope and complexities of the project. Management also explained that the project had a very tight deadline due to the start of school and arrival of students. Further, a shortage of labor and capacity in the local construction industry was observed by management, limiting the number of contractors willing and able to commit to the scope and deadlines of the project. For these reasons, management explained that it was impractical to obtain bids/quotes. Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with the those requirements prior to June 30, 2023.