Audit 289667

FY End
2023-06-30
Total Expended
$1.98M
Findings
10
Programs
13
Year: 2023 Accepted: 2024-02-09

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
366692 2023-004 Significant Deficiency Yes I
366693 2023-004 Significant Deficiency Yes I
366694 2023-004 Significant Deficiency Yes I
366695 2023-004 Significant Deficiency Yes I
366696 2023-004 Significant Deficiency Yes I
943134 2023-004 Significant Deficiency Yes I
943135 2023-004 Significant Deficiency Yes I
943136 2023-004 Significant Deficiency Yes I
943137 2023-004 Significant Deficiency Yes I
943138 2023-004 Significant Deficiency Yes I

Contacts

Name Title Type
FUVACBG6AEY8 Lori Robertson Auditee
3198284510 Mia Frommelt Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards are reported on the modified accrual or accrual basis of accounting based on the fund-type of the program. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in or used in the preparation of the basic financial statements. Revenue from federal awards is recognized when the District has done everything necessary to establish its right to revenue. For governmental funds, revenue from federal awards is recognized when it is both measurable and available. Expenditures of federal awards are recognized in the accounting period when the liability is incurred. De Minimis Rate Used: N Rate Explanation: The District has elected not to use the 10-percent de minimus indirect cost rate allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards includes the federal grant activity of the Clear Creek Amana Community School District under programs of the federal government for the year ended June 30, 2023. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of Clear Creek Amana Community School District, it is not intended to and does not present the financial position, changes in net position or cash flows of Clear Creek Amana Community School District.
Title: Note 2. Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards are reported on the modified accrual or accrual basis of accounting based on the fund-type of the program. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in or used in the preparation of the basic financial statements. Revenue from federal awards is recognized when the District has done everything necessary to establish its right to revenue. For governmental funds, revenue from federal awards is recognized when it is both measurable and available. Expenditures of federal awards are recognized in the accounting period when the liability is incurred. De Minimis Rate Used: N Rate Explanation: The District has elected not to use the 10-percent de minimus indirect cost rate allowed under the Uniform Guidance. Expenditures reported on the Schedule of Expenditures of Federal Awards are reported on the modified accrual or accrual basis of accounting based on the fund-type of the program. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in or used in the preparation of the basic financial statements. Revenue from federal awards is recognized when the District has done everything necessary to establish its right to revenue. For governmental funds, revenue from federal awards is recognized when it is both measurable and available. Expenditures of federal awards are recognized in the accounting period when the liability is incurred.
Title: Note 3. Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards are reported on the modified accrual or accrual basis of accounting based on the fund-type of the program. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in or used in the preparation of the basic financial statements. Revenue from federal awards is recognized when the District has done everything necessary to establish its right to revenue. For governmental funds, revenue from federal awards is recognized when it is both measurable and available. Expenditures of federal awards are recognized in the accounting period when the liability is incurred. De Minimis Rate Used: N Rate Explanation: The District has elected not to use the 10-percent de minimus indirect cost rate allowed under the Uniform Guidance. The District has elected not to use the 10-percent de minimus indirect cost rate allowed under the Uniform Guidance.

Finding Details

U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.
U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.
U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.
U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.
U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.
U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.
U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.
U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.
U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.
U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.