2 C.F.R. ? 400.1 gives regulatory effect to the Department of Agriculture for 2 C.F.R. ? 200.318(a) which requires the School District to use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section. 2 C.F.R. ? 200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and 2 C.F.R.? 200.320. 2 C.F.R ? 200.320 requires procurement to be performed through micro-purchase procedures, small purchase procedures, sealed bids, competitive proposals or noncompetitive proposals when only one source was available. Furthermore, 2 C.F.R. ? 200.318(i) provides that the entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District implemented policy # DECA ? Administration of Federal Grant Funds, last revised on September 14, 2020. However, the policy did not document procurement performed through micro-purchase procedures. Procurement by micro-purchase was the acquisition of supplies or services, the aggregate dollar amount of which does not exceed $3,500. To the extent practicable, the School District must distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the School District considers the price to be reasonable. The National Defense Authorization Act of 2018 allowed entities to increase the micro-purchase threshold from $3,500 to $10,000. However, this increase was required to be formally adopted by policy. As this was not formally approved, the School District was subject to the $3,500 threshold. During 2022, the School District purchased items from eight vendors with federal nutrition monies exceeding the $3,500 threshold where they did not ensure open competition by seeking multiple quotes. As a result, the School District did not ensure open competition through procurement. The School District should review their policy and the requirements of 2 C.F.R. ?? 200.318 through 200.320, as well as the National Defense Authorization Act of 2018. The School District should update their policy to include procurement by micro-purchases with a limit of either $3,500 or $10,000, as desired. The School District should ensure open competition has occurred by seeking multiple quotes for expenditures aggregating to more than the threshold per vendor, utilizing the required number of quotes as documented in their policy. For expenditures within the approved micro-purchase threshold, the School District should, to the extent practicable, distribute micro-purchases among vendors. This will help to ensure that the School District?s policies meet federal requirements, and the School District ensures open competition through procurement.
7 C.F.R. ? 245.6a required the School District to verify select free and reduced food service applications. The verification process includes selecting a sample of applications and obtaining written documentation regarding income. 7 C.F.R. ? 245.6a, paragraph (a)(7) documents that sources of information for verification include written evidence, collateral contacts, and systems of records. Written evidence shall be used as the primary source of information for verification. Written evidence includes written confirmation of a household?s circumstances, such as wage stubs, award letters, and letters from employers. Whenever written evidence is insufficient to confirm income information on the application or current eligibility, the local educational agency may require collateral contacts. Collateral contacts are verbal confirmations of a household?s circumstances by a person outside of the household. Agency records to which the State agency or local educational agency may have access can also be utilized for verification. The School District selected six applications for verification. One family verbally communicated their household earnings to the School District and later submitted a wage stub within the verification time period. However, the School District utilized the verbal earnings amount in the verification process rather than using the family's wage stub, resulting in the family receiving free status rather than denied or full pay status. Furthermore, this would have led to receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to this family's actual benefit usage. The School District should review the annual ?Ohio Department of Education Office for Child Nutrition - Verification Instruction Manual? as well as the Federal requirements outlined within 7 C.F.R. ? 245.6a. All verifications should be performed in accordance with the manual and be performed by someone other than the original verifying official on the initial application. Additionally, all income documentation should be reviewed to ensure that amounts entered into the food service management system are correct. These procedures will help to ensure that benefits are correctly calculated and provided as well as help to ensure that the School District is not over or under reimbursed for claimed free and reduced lunches.
2 C.F.R. ? 400.1 gives regulatory effect to the Department of Agriculture for 2 C.F.R. ? 200.318(a) which requires the School District to use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section. 2 C.F.R. ? 200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and 2 C.F.R.? 200.320. 2 C.F.R ? 200.320 requires procurement to be performed through micro-purchase procedures, small purchase procedures, sealed bids, competitive proposals or noncompetitive proposals when only one source was available. Furthermore, 2 C.F.R. ? 200.318(i) provides that the entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District implemented policy # DECA ? Administration of Federal Grant Funds, last revised on September 14, 2020. However, the policy did not document procurement performed through micro-purchase procedures. Procurement by micro-purchase was the acquisition of supplies or services, the aggregate dollar amount of which does not exceed $3,500. To the extent practicable, the School District must distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the School District considers the price to be reasonable. The National Defense Authorization Act of 2018 allowed entities to increase the micro-purchase threshold from $3,500 to $10,000. However, this increase was required to be formally adopted by policy. As this was not formally approved, the School District was subject to the $3,500 threshold. During 2022, the School District purchased items from eight vendors with federal nutrition monies exceeding the $3,500 threshold where they did not ensure open competition by seeking multiple quotes. As a result, the School District did not ensure open competition through procurement. The School District should review their policy and the requirements of 2 C.F.R. ?? 200.318 through 200.320, as well as the National Defense Authorization Act of 2018. The School District should update their policy to include procurement by micro-purchases with a limit of either $3,500 or $10,000, as desired. The School District should ensure open competition has occurred by seeking multiple quotes for expenditures aggregating to more than the threshold per vendor, utilizing the required number of quotes as documented in their policy. For expenditures within the approved micro-purchase threshold, the School District should, to the extent practicable, distribute micro-purchases among vendors. This will help to ensure that the School District?s policies meet federal requirements, and the School District ensures open competition through procurement.
7 C.F.R. ? 245.6a required the School District to verify select free and reduced food service applications. The verification process includes selecting a sample of applications and obtaining written documentation regarding income. 7 C.F.R. ? 245.6a, paragraph (a)(7) documents that sources of information for verification include written evidence, collateral contacts, and systems of records. Written evidence shall be used as the primary source of information for verification. Written evidence includes written confirmation of a household?s circumstances, such as wage stubs, award letters, and letters from employers. Whenever written evidence is insufficient to confirm income information on the application or current eligibility, the local educational agency may require collateral contacts. Collateral contacts are verbal confirmations of a household?s circumstances by a person outside of the household. Agency records to which the State agency or local educational agency may have access can also be utilized for verification. The School District selected six applications for verification. One family verbally communicated their household earnings to the School District and later submitted a wage stub within the verification time period. However, the School District utilized the verbal earnings amount in the verification process rather than using the family's wage stub, resulting in the family receiving free status rather than denied or full pay status. Furthermore, this would have led to receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to this family's actual benefit usage. The School District should review the annual ?Ohio Department of Education Office for Child Nutrition - Verification Instruction Manual? as well as the Federal requirements outlined within 7 C.F.R. ? 245.6a. All verifications should be performed in accordance with the manual and be performed by someone other than the original verifying official on the initial application. Additionally, all income documentation should be reviewed to ensure that amounts entered into the food service management system are correct. These procedures will help to ensure that benefits are correctly calculated and provided as well as help to ensure that the School District is not over or under reimbursed for claimed free and reduced lunches.
2 C.F.R. ? 400.1 gives regulatory effect to the Department of Agriculture for 2 C.F.R. ? 200.318(a) which requires the School District to use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section. 2 C.F.R. ? 200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and 2 C.F.R.? 200.320. 2 C.F.R ? 200.320 requires procurement to be performed through micro-purchase procedures, small purchase procedures, sealed bids, competitive proposals or noncompetitive proposals when only one source was available. Furthermore, 2 C.F.R. ? 200.318(i) provides that the entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District implemented policy # DECA ? Administration of Federal Grant Funds, last revised on September 14, 2020. However, the policy did not document procurement performed through micro-purchase procedures. Procurement by micro-purchase was the acquisition of supplies or services, the aggregate dollar amount of which does not exceed $3,500. To the extent practicable, the School District must distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the School District considers the price to be reasonable. The National Defense Authorization Act of 2018 allowed entities to increase the micro-purchase threshold from $3,500 to $10,000. However, this increase was required to be formally adopted by policy. As this was not formally approved, the School District was subject to the $3,500 threshold. During 2022, the School District purchased items from eight vendors with federal nutrition monies exceeding the $3,500 threshold where they did not ensure open competition by seeking multiple quotes. As a result, the School District did not ensure open competition through procurement. The School District should review their policy and the requirements of 2 C.F.R. ?? 200.318 through 200.320, as well as the National Defense Authorization Act of 2018. The School District should update their policy to include procurement by micro-purchases with a limit of either $3,500 or $10,000, as desired. The School District should ensure open competition has occurred by seeking multiple quotes for expenditures aggregating to more than the threshold per vendor, utilizing the required number of quotes as documented in their policy. For expenditures within the approved micro-purchase threshold, the School District should, to the extent practicable, distribute micro-purchases among vendors. This will help to ensure that the School District?s policies meet federal requirements, and the School District ensures open competition through procurement.
7 C.F.R. ? 245.6a required the School District to verify select free and reduced food service applications. The verification process includes selecting a sample of applications and obtaining written documentation regarding income. 7 C.F.R. ? 245.6a, paragraph (a)(7) documents that sources of information for verification include written evidence, collateral contacts, and systems of records. Written evidence shall be used as the primary source of information for verification. Written evidence includes written confirmation of a household?s circumstances, such as wage stubs, award letters, and letters from employers. Whenever written evidence is insufficient to confirm income information on the application or current eligibility, the local educational agency may require collateral contacts. Collateral contacts are verbal confirmations of a household?s circumstances by a person outside of the household. Agency records to which the State agency or local educational agency may have access can also be utilized for verification. The School District selected six applications for verification. One family verbally communicated their household earnings to the School District and later submitted a wage stub within the verification time period. However, the School District utilized the verbal earnings amount in the verification process rather than using the family's wage stub, resulting in the family receiving free status rather than denied or full pay status. Furthermore, this would have led to receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to this family's actual benefit usage. The School District should review the annual ?Ohio Department of Education Office for Child Nutrition - Verification Instruction Manual? as well as the Federal requirements outlined within 7 C.F.R. ? 245.6a. All verifications should be performed in accordance with the manual and be performed by someone other than the original verifying official on the initial application. Additionally, all income documentation should be reviewed to ensure that amounts entered into the food service management system are correct. These procedures will help to ensure that benefits are correctly calculated and provided as well as help to ensure that the School District is not over or under reimbursed for claimed free and reduced lunches.
2 C.F.R. ? 400.1 gives regulatory effect to the Department of Agriculture for 2 C.F.R. ? 200.318(a) which requires the School District to use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section. 2 C.F.R. ? 200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and 2 C.F.R.? 200.320. 2 C.F.R ? 200.320 requires procurement to be performed through micro-purchase procedures, small purchase procedures, sealed bids, competitive proposals or noncompetitive proposals when only one source was available. Furthermore, 2 C.F.R. ? 200.318(i) provides that the entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District implemented policy # DECA ? Administration of Federal Grant Funds, last revised on September 14, 2020. However, the policy did not document procurement performed through micro-purchase procedures. Procurement by micro-purchase was the acquisition of supplies or services, the aggregate dollar amount of which does not exceed $3,500. To the extent practicable, the School District must distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the School District considers the price to be reasonable. The National Defense Authorization Act of 2018 allowed entities to increase the micro-purchase threshold from $3,500 to $10,000. However, this increase was required to be formally adopted by policy. As this was not formally approved, the School District was subject to the $3,500 threshold. During 2022, the School District purchased items from eight vendors with federal nutrition monies exceeding the $3,500 threshold where they did not ensure open competition by seeking multiple quotes. As a result, the School District did not ensure open competition through procurement. The School District should review their policy and the requirements of 2 C.F.R. ?? 200.318 through 200.320, as well as the National Defense Authorization Act of 2018. The School District should update their policy to include procurement by micro-purchases with a limit of either $3,500 or $10,000, as desired. The School District should ensure open competition has occurred by seeking multiple quotes for expenditures aggregating to more than the threshold per vendor, utilizing the required number of quotes as documented in their policy. For expenditures within the approved micro-purchase threshold, the School District should, to the extent practicable, distribute micro-purchases among vendors. This will help to ensure that the School District?s policies meet federal requirements, and the School District ensures open competition through procurement.
7 C.F.R. ? 245.6a required the School District to verify select free and reduced food service applications. The verification process includes selecting a sample of applications and obtaining written documentation regarding income. 7 C.F.R. ? 245.6a, paragraph (a)(7) documents that sources of information for verification include written evidence, collateral contacts, and systems of records. Written evidence shall be used as the primary source of information for verification. Written evidence includes written confirmation of a household?s circumstances, such as wage stubs, award letters, and letters from employers. Whenever written evidence is insufficient to confirm income information on the application or current eligibility, the local educational agency may require collateral contacts. Collateral contacts are verbal confirmations of a household?s circumstances by a person outside of the household. Agency records to which the State agency or local educational agency may have access can also be utilized for verification. The School District selected six applications for verification. One family verbally communicated their household earnings to the School District and later submitted a wage stub within the verification time period. However, the School District utilized the verbal earnings amount in the verification process rather than using the family's wage stub, resulting in the family receiving free status rather than denied or full pay status. Furthermore, this would have led to receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to this family's actual benefit usage. The School District should review the annual ?Ohio Department of Education Office for Child Nutrition - Verification Instruction Manual? as well as the Federal requirements outlined within 7 C.F.R. ? 245.6a. All verifications should be performed in accordance with the manual and be performed by someone other than the original verifying official on the initial application. Additionally, all income documentation should be reviewed to ensure that amounts entered into the food service management system are correct. These procedures will help to ensure that benefits are correctly calculated and provided as well as help to ensure that the School District is not over or under reimbursed for claimed free and reduced lunches.
2 C.F.R. ? 400.1 gives regulatory effect to the Department of Agriculture for 2 C.F.R. ? 200.318(a) which requires the School District to use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section. 2 C.F.R. ? 200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and 2 C.F.R.? 200.320. 2 C.F.R ? 200.320 requires procurement to be performed through micro-purchase procedures, small purchase procedures, sealed bids, competitive proposals or noncompetitive proposals when only one source was available. Furthermore, 2 C.F.R. ? 200.318(i) provides that the entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District implemented policy # DECA ? Administration of Federal Grant Funds, last revised on September 14, 2020. However, the policy did not document procurement performed through micro-purchase procedures. Procurement by micro-purchase was the acquisition of supplies or services, the aggregate dollar amount of which does not exceed $3,500. To the extent practicable, the School District must distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the School District considers the price to be reasonable. The National Defense Authorization Act of 2018 allowed entities to increase the micro-purchase threshold from $3,500 to $10,000. However, this increase was required to be formally adopted by policy. As this was not formally approved, the School District was subject to the $3,500 threshold. During 2022, the School District purchased items from eight vendors with federal nutrition monies exceeding the $3,500 threshold where they did not ensure open competition by seeking multiple quotes. As a result, the School District did not ensure open competition through procurement. The School District should review their policy and the requirements of 2 C.F.R. ?? 200.318 through 200.320, as well as the National Defense Authorization Act of 2018. The School District should update their policy to include procurement by micro-purchases with a limit of either $3,500 or $10,000, as desired. The School District should ensure open competition has occurred by seeking multiple quotes for expenditures aggregating to more than the threshold per vendor, utilizing the required number of quotes as documented in their policy. For expenditures within the approved micro-purchase threshold, the School District should, to the extent practicable, distribute micro-purchases among vendors. This will help to ensure that the School District?s policies meet federal requirements, and the School District ensures open competition through procurement.
7 C.F.R. ? 245.6a required the School District to verify select free and reduced food service applications. The verification process includes selecting a sample of applications and obtaining written documentation regarding income. 7 C.F.R. ? 245.6a, paragraph (a)(7) documents that sources of information for verification include written evidence, collateral contacts, and systems of records. Written evidence shall be used as the primary source of information for verification. Written evidence includes written confirmation of a household?s circumstances, such as wage stubs, award letters, and letters from employers. Whenever written evidence is insufficient to confirm income information on the application or current eligibility, the local educational agency may require collateral contacts. Collateral contacts are verbal confirmations of a household?s circumstances by a person outside of the household. Agency records to which the State agency or local educational agency may have access can also be utilized for verification. The School District selected six applications for verification. One family verbally communicated their household earnings to the School District and later submitted a wage stub within the verification time period. However, the School District utilized the verbal earnings amount in the verification process rather than using the family's wage stub, resulting in the family receiving free status rather than denied or full pay status. Furthermore, this would have led to receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to this family's actual benefit usage. The School District should review the annual ?Ohio Department of Education Office for Child Nutrition - Verification Instruction Manual? as well as the Federal requirements outlined within 7 C.F.R. ? 245.6a. All verifications should be performed in accordance with the manual and be performed by someone other than the original verifying official on the initial application. Additionally, all income documentation should be reviewed to ensure that amounts entered into the food service management system are correct. These procedures will help to ensure that benefits are correctly calculated and provided as well as help to ensure that the School District is not over or under reimbursed for claimed free and reduced lunches.
2 C.F.R. ? 400.1 gives regulatory effect to the Department of Agriculture for 2 C.F.R. ? 200.318(a) which requires the School District to use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section. 2 C.F.R. ? 200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and 2 C.F.R.? 200.320. 2 C.F.R ? 200.320 requires procurement to be performed through micro-purchase procedures, small purchase procedures, sealed bids, competitive proposals or noncompetitive proposals when only one source was available. Furthermore, 2 C.F.R. ? 200.318(i) provides that the entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District implemented policy # DECA ? Administration of Federal Grant Funds, last revised on September 14, 2020. However, the policy did not document procurement performed through micro-purchase procedures. Procurement by micro-purchase was the acquisition of supplies or services, the aggregate dollar amount of which does not exceed $3,500. To the extent practicable, the School District must distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the School District considers the price to be reasonable. The National Defense Authorization Act of 2018 allowed entities to increase the micro-purchase threshold from $3,500 to $10,000. However, this increase was required to be formally adopted by policy. As this was not formally approved, the School District was subject to the $3,500 threshold. During 2022, the School District purchased items from eight vendors with federal nutrition monies exceeding the $3,500 threshold where they did not ensure open competition by seeking multiple quotes. As a result, the School District did not ensure open competition through procurement. The School District should review their policy and the requirements of 2 C.F.R. ?? 200.318 through 200.320, as well as the National Defense Authorization Act of 2018. The School District should update their policy to include procurement by micro-purchases with a limit of either $3,500 or $10,000, as desired. The School District should ensure open competition has occurred by seeking multiple quotes for expenditures aggregating to more than the threshold per vendor, utilizing the required number of quotes as documented in their policy. For expenditures within the approved micro-purchase threshold, the School District should, to the extent practicable, distribute micro-purchases among vendors. This will help to ensure that the School District?s policies meet federal requirements, and the School District ensures open competition through procurement.
7 C.F.R. ? 245.6a required the School District to verify select free and reduced food service applications. The verification process includes selecting a sample of applications and obtaining written documentation regarding income. 7 C.F.R. ? 245.6a, paragraph (a)(7) documents that sources of information for verification include written evidence, collateral contacts, and systems of records. Written evidence shall be used as the primary source of information for verification. Written evidence includes written confirmation of a household?s circumstances, such as wage stubs, award letters, and letters from employers. Whenever written evidence is insufficient to confirm income information on the application or current eligibility, the local educational agency may require collateral contacts. Collateral contacts are verbal confirmations of a household?s circumstances by a person outside of the household. Agency records to which the State agency or local educational agency may have access can also be utilized for verification. The School District selected six applications for verification. One family verbally communicated their household earnings to the School District and later submitted a wage stub within the verification time period. However, the School District utilized the verbal earnings amount in the verification process rather than using the family's wage stub, resulting in the family receiving free status rather than denied or full pay status. Furthermore, this would have led to receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to this family's actual benefit usage. The School District should review the annual ?Ohio Department of Education Office for Child Nutrition - Verification Instruction Manual? as well as the Federal requirements outlined within 7 C.F.R. ? 245.6a. All verifications should be performed in accordance with the manual and be performed by someone other than the original verifying official on the initial application. Additionally, all income documentation should be reviewed to ensure that amounts entered into the food service management system are correct. These procedures will help to ensure that benefits are correctly calculated and provided as well as help to ensure that the School District is not over or under reimbursed for claimed free and reduced lunches.
2 C.F.R. ? 400.1 gives regulatory effect to the Department of Agriculture for 2 C.F.R. ? 200.318(a) which requires the School District to use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section. 2 C.F.R. ? 200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and 2 C.F.R.? 200.320. 2 C.F.R ? 200.320 requires procurement to be performed through micro-purchase procedures, small purchase procedures, sealed bids, competitive proposals or noncompetitive proposals when only one source was available. Furthermore, 2 C.F.R. ? 200.318(i) provides that the entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District implemented policy # DECA ? Administration of Federal Grant Funds, last revised on September 14, 2020. However, the policy did not document procurement performed through micro-purchase procedures. Procurement by micro-purchase was the acquisition of supplies or services, the aggregate dollar amount of which does not exceed $3,500. To the extent practicable, the School District must distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the School District considers the price to be reasonable. The National Defense Authorization Act of 2018 allowed entities to increase the micro-purchase threshold from $3,500 to $10,000. However, this increase was required to be formally adopted by policy. As this was not formally approved, the School District was subject to the $3,500 threshold. During 2022, the School District purchased items from eight vendors with federal nutrition monies exceeding the $3,500 threshold where they did not ensure open competition by seeking multiple quotes. As a result, the School District did not ensure open competition through procurement. The School District should review their policy and the requirements of 2 C.F.R. ?? 200.318 through 200.320, as well as the National Defense Authorization Act of 2018. The School District should update their policy to include procurement by micro-purchases with a limit of either $3,500 or $10,000, as desired. The School District should ensure open competition has occurred by seeking multiple quotes for expenditures aggregating to more than the threshold per vendor, utilizing the required number of quotes as documented in their policy. For expenditures within the approved micro-purchase threshold, the School District should, to the extent practicable, distribute micro-purchases among vendors. This will help to ensure that the School District?s policies meet federal requirements, and the School District ensures open competition through procurement.
7 C.F.R. ? 245.6a required the School District to verify select free and reduced food service applications. The verification process includes selecting a sample of applications and obtaining written documentation regarding income. 7 C.F.R. ? 245.6a, paragraph (a)(7) documents that sources of information for verification include written evidence, collateral contacts, and systems of records. Written evidence shall be used as the primary source of information for verification. Written evidence includes written confirmation of a household?s circumstances, such as wage stubs, award letters, and letters from employers. Whenever written evidence is insufficient to confirm income information on the application or current eligibility, the local educational agency may require collateral contacts. Collateral contacts are verbal confirmations of a household?s circumstances by a person outside of the household. Agency records to which the State agency or local educational agency may have access can also be utilized for verification. The School District selected six applications for verification. One family verbally communicated their household earnings to the School District and later submitted a wage stub within the verification time period. However, the School District utilized the verbal earnings amount in the verification process rather than using the family's wage stub, resulting in the family receiving free status rather than denied or full pay status. Furthermore, this would have led to receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to this family's actual benefit usage. The School District should review the annual ?Ohio Department of Education Office for Child Nutrition - Verification Instruction Manual? as well as the Federal requirements outlined within 7 C.F.R. ? 245.6a. All verifications should be performed in accordance with the manual and be performed by someone other than the original verifying official on the initial application. Additionally, all income documentation should be reviewed to ensure that amounts entered into the food service management system are correct. These procedures will help to ensure that benefits are correctly calculated and provided as well as help to ensure that the School District is not over or under reimbursed for claimed free and reduced lunches.
2 C.F.R. ? 400.1 gives regulatory effect to the Department of Agriculture for 2 C.F.R. ? 200.318(a) which requires the School District to use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section. 2 C.F.R. ? 200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and 2 C.F.R.? 200.320. 2 C.F.R ? 200.320 requires procurement to be performed through micro-purchase procedures, small purchase procedures, sealed bids, competitive proposals or noncompetitive proposals when only one source was available. Furthermore, 2 C.F.R. ? 200.318(i) provides that the entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District implemented policy # DECA ? Administration of Federal Grant Funds, last revised on September 14, 2020. However, the policy did not document procurement performed through micro-purchase procedures. Procurement by micro-purchase was the acquisition of supplies or services, the aggregate dollar amount of which does not exceed $3,500. To the extent practicable, the School District must distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the School District considers the price to be reasonable. The National Defense Authorization Act of 2018 allowed entities to increase the micro-purchase threshold from $3,500 to $10,000. However, this increase was required to be formally adopted by policy. As this was not formally approved, the School District was subject to the $3,500 threshold. During 2022, the School District purchased items from eight vendors with federal nutrition monies exceeding the $3,500 threshold where they did not ensure open competition by seeking multiple quotes. As a result, the School District did not ensure open competition through procurement. The School District should review their policy and the requirements of 2 C.F.R. ?? 200.318 through 200.320, as well as the National Defense Authorization Act of 2018. The School District should update their policy to include procurement by micro-purchases with a limit of either $3,500 or $10,000, as desired. The School District should ensure open competition has occurred by seeking multiple quotes for expenditures aggregating to more than the threshold per vendor, utilizing the required number of quotes as documented in their policy. For expenditures within the approved micro-purchase threshold, the School District should, to the extent practicable, distribute micro-purchases among vendors. This will help to ensure that the School District?s policies meet federal requirements, and the School District ensures open competition through procurement.
7 C.F.R. ? 245.6a required the School District to verify select free and reduced food service applications. The verification process includes selecting a sample of applications and obtaining written documentation regarding income. 7 C.F.R. ? 245.6a, paragraph (a)(7) documents that sources of information for verification include written evidence, collateral contacts, and systems of records. Written evidence shall be used as the primary source of information for verification. Written evidence includes written confirmation of a household?s circumstances, such as wage stubs, award letters, and letters from employers. Whenever written evidence is insufficient to confirm income information on the application or current eligibility, the local educational agency may require collateral contacts. Collateral contacts are verbal confirmations of a household?s circumstances by a person outside of the household. Agency records to which the State agency or local educational agency may have access can also be utilized for verification. The School District selected six applications for verification. One family verbally communicated their household earnings to the School District and later submitted a wage stub within the verification time period. However, the School District utilized the verbal earnings amount in the verification process rather than using the family's wage stub, resulting in the family receiving free status rather than denied or full pay status. Furthermore, this would have led to receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to this family's actual benefit usage. The School District should review the annual ?Ohio Department of Education Office for Child Nutrition - Verification Instruction Manual? as well as the Federal requirements outlined within 7 C.F.R. ? 245.6a. All verifications should be performed in accordance with the manual and be performed by someone other than the original verifying official on the initial application. Additionally, all income documentation should be reviewed to ensure that amounts entered into the food service management system are correct. These procedures will help to ensure that benefits are correctly calculated and provided as well as help to ensure that the School District is not over or under reimbursed for claimed free and reduced lunches.