Finding 2023-003: Reporting (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible
students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11,
215.10, and 225.15(c)). Each month’s claim for reimbursement and all data used in the claims review process must
be maintained on file. Accurate records must be maintained justifying all meals claimed. Failure to maintain such
records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the
period covered by the records in question. Records are required to be retained for a period of three years after
submission of the final Claim for Reimbursement for the fiscal year.
Condition: From August 2022 through January 2023, all meals served were being hand tallied. Only total meals
served were counted and there were no records maintained to document the free/reduced/paid status of the students
receiving meals. At the end of the month, the District was applying an estimated percentage breakout of
free/reduced/paid to the total meal counts, and using this estimate on their monthly CNIPS claim forms. In addition,
the total meals documented on the District tally sheets could not be consistently reconciled to the total meals
claimed for the two months sampled for testing (September 2022 and January 2023). In February 2023, the District
implemented a point of sale system and began tracking meals by Free/reduced/paid status and reconciling system
records to claim forms.
Cause: Due to turnover at the District and changing procedures after COVID, the District experienced a delayed
implementation of their point of sale system and continued tracking total meals by hand like they had done under the
previous COVID flexibility waivers.
Context: Discrepancies were noted for the months of August 2022 through January 2023.
Effect: Meals reported could not be reconciled to total meals served or eligibility status of participating students.
This could cause inaccurately claimed meal counts and inappropriate reimbursement rates based on
free/reduced/paid eligibility.
Questioned Cost: There was insufficient documentation to determine the total meals served or the breakout
between free, reduced, and paid meals, therefore, a questioned cost cannot be calculated. The total child nutrition
funding claimed for the six months in question was $254,604 Federal and $236,725 State.
Recommendation: We recommend that the District continue to utilize a point of sale system and track all meals
served by student eligibility. We further recommend that these records be reconciled against claim forms on a
monthly basis.
Views of Responsible Officials: The District started the 2022-23 school year without a point of sale system in
place. The rollout of a new point of sale system took until January to get up at all sites and therefore created
challenges for the cafeteria staff to keep up with keeping accurate records for meal claims.
The point of sale has been in place at all sites since January 2023 and has not had issues related to tracking meal
participation. The District is prioritizing systems that synchronize with the student information system to ensure
accurate data is shared across all aspects of school operations that get reported through CALPADS.
Finding 2023-004: Procurement (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented
procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the
acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where
the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified
acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as
determined appropriate by the non-Federal entity.
Condition: During our testing of procurement, we sampled three contracts that would qualify as “small purchases.”
The District could not provide evidence that multiple quotes had been obtained prior to selecting any of the three
vendors.
Cause: Due to high turnover at the District, there has been a lack of oversight to ensure all appropriate
documentation is maintained to demonstrate that the District is in compliance with Public Contract Code and that
purchases are awarded after a reasonable number of quotes have been obtained.
Context: Deficiency was noted in all three contracts tested.
Effect: Contracts were awarded without following proper procurement procedures.
Questioned Cost: This resulted in roughly $86,000 awarded in contracts, without following proper procedures.
Recommendation: We recommend that the District train and implement the required federal procurement
procedures to ensure that the District is in compliance.
Views of Responsible Officials: The District is working to ensure that management staff understand the
requirements of federal procurement for our meal program. The cafeteria program also had a Procurement Review
process with CDE staff about its procurement procedures in the 2022-23 school year. This training provided
valuable information and will help the District with compliance.
Finding 2023-003: Reporting (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible
students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11,
215.10, and 225.15(c)). Each month’s claim for reimbursement and all data used in the claims review process must
be maintained on file. Accurate records must be maintained justifying all meals claimed. Failure to maintain such
records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the
period covered by the records in question. Records are required to be retained for a period of three years after
submission of the final Claim for Reimbursement for the fiscal year.
Condition: From August 2022 through January 2023, all meals served were being hand tallied. Only total meals
served were counted and there were no records maintained to document the free/reduced/paid status of the students
receiving meals. At the end of the month, the District was applying an estimated percentage breakout of
free/reduced/paid to the total meal counts, and using this estimate on their monthly CNIPS claim forms. In addition,
the total meals documented on the District tally sheets could not be consistently reconciled to the total meals
claimed for the two months sampled for testing (September 2022 and January 2023). In February 2023, the District
implemented a point of sale system and began tracking meals by Free/reduced/paid status and reconciling system
records to claim forms.
Cause: Due to turnover at the District and changing procedures after COVID, the District experienced a delayed
implementation of their point of sale system and continued tracking total meals by hand like they had done under the
previous COVID flexibility waivers.
Context: Discrepancies were noted for the months of August 2022 through January 2023.
Effect: Meals reported could not be reconciled to total meals served or eligibility status of participating students.
This could cause inaccurately claimed meal counts and inappropriate reimbursement rates based on
free/reduced/paid eligibility.
Questioned Cost: There was insufficient documentation to determine the total meals served or the breakout
between free, reduced, and paid meals, therefore, a questioned cost cannot be calculated. The total child nutrition
funding claimed for the six months in question was $254,604 Federal and $236,725 State.
Recommendation: We recommend that the District continue to utilize a point of sale system and track all meals
served by student eligibility. We further recommend that these records be reconciled against claim forms on a
monthly basis.
Views of Responsible Officials: The District started the 2022-23 school year without a point of sale system in
place. The rollout of a new point of sale system took until January to get up at all sites and therefore created
challenges for the cafeteria staff to keep up with keeping accurate records for meal claims.
The point of sale has been in place at all sites since January 2023 and has not had issues related to tracking meal
participation. The District is prioritizing systems that synchronize with the student information system to ensure
accurate data is shared across all aspects of school operations that get reported through CALPADS.
Finding 2023-004: Procurement (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented
procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the
acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where
the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified
acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as
determined appropriate by the non-Federal entity.
Condition: During our testing of procurement, we sampled three contracts that would qualify as “small purchases.”
The District could not provide evidence that multiple quotes had been obtained prior to selecting any of the three
vendors.
Cause: Due to high turnover at the District, there has been a lack of oversight to ensure all appropriate
documentation is maintained to demonstrate that the District is in compliance with Public Contract Code and that
purchases are awarded after a reasonable number of quotes have been obtained.
Context: Deficiency was noted in all three contracts tested.
Effect: Contracts were awarded without following proper procurement procedures.
Questioned Cost: This resulted in roughly $86,000 awarded in contracts, without following proper procedures.
Recommendation: We recommend that the District train and implement the required federal procurement
procedures to ensure that the District is in compliance.
Views of Responsible Officials: The District is working to ensure that management staff understand the
requirements of federal procurement for our meal program. The cafeteria program also had a Procurement Review
process with CDE staff about its procurement procedures in the 2022-23 school year. This training provided
valuable information and will help the District with compliance.
Finding 2023-003: Reporting (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible
students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11,
215.10, and 225.15(c)). Each month’s claim for reimbursement and all data used in the claims review process must
be maintained on file. Accurate records must be maintained justifying all meals claimed. Failure to maintain such
records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the
period covered by the records in question. Records are required to be retained for a period of three years after
submission of the final Claim for Reimbursement for the fiscal year.
Condition: From August 2022 through January 2023, all meals served were being hand tallied. Only total meals
served were counted and there were no records maintained to document the free/reduced/paid status of the students
receiving meals. At the end of the month, the District was applying an estimated percentage breakout of
free/reduced/paid to the total meal counts, and using this estimate on their monthly CNIPS claim forms. In addition,
the total meals documented on the District tally sheets could not be consistently reconciled to the total meals
claimed for the two months sampled for testing (September 2022 and January 2023). In February 2023, the District
implemented a point of sale system and began tracking meals by Free/reduced/paid status and reconciling system
records to claim forms.
Cause: Due to turnover at the District and changing procedures after COVID, the District experienced a delayed
implementation of their point of sale system and continued tracking total meals by hand like they had done under the
previous COVID flexibility waivers.
Context: Discrepancies were noted for the months of August 2022 through January 2023.
Effect: Meals reported could not be reconciled to total meals served or eligibility status of participating students.
This could cause inaccurately claimed meal counts and inappropriate reimbursement rates based on
free/reduced/paid eligibility.
Questioned Cost: There was insufficient documentation to determine the total meals served or the breakout
between free, reduced, and paid meals, therefore, a questioned cost cannot be calculated. The total child nutrition
funding claimed for the six months in question was $254,604 Federal and $236,725 State.
Recommendation: We recommend that the District continue to utilize a point of sale system and track all meals
served by student eligibility. We further recommend that these records be reconciled against claim forms on a
monthly basis.
Views of Responsible Officials: The District started the 2022-23 school year without a point of sale system in
place. The rollout of a new point of sale system took until January to get up at all sites and therefore created
challenges for the cafeteria staff to keep up with keeping accurate records for meal claims.
The point of sale has been in place at all sites since January 2023 and has not had issues related to tracking meal
participation. The District is prioritizing systems that synchronize with the student information system to ensure
accurate data is shared across all aspects of school operations that get reported through CALPADS.
Finding 2023-004: Procurement (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented
procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the
acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where
the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified
acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as
determined appropriate by the non-Federal entity.
Condition: During our testing of procurement, we sampled three contracts that would qualify as “small purchases.”
The District could not provide evidence that multiple quotes had been obtained prior to selecting any of the three
vendors.
Cause: Due to high turnover at the District, there has been a lack of oversight to ensure all appropriate
documentation is maintained to demonstrate that the District is in compliance with Public Contract Code and that
purchases are awarded after a reasonable number of quotes have been obtained.
Context: Deficiency was noted in all three contracts tested.
Effect: Contracts were awarded without following proper procurement procedures.
Questioned Cost: This resulted in roughly $86,000 awarded in contracts, without following proper procedures.
Recommendation: We recommend that the District train and implement the required federal procurement
procedures to ensure that the District is in compliance.
Views of Responsible Officials: The District is working to ensure that management staff understand the
requirements of federal procurement for our meal program. The cafeteria program also had a Procurement Review
process with CDE staff about its procurement procedures in the 2022-23 school year. This training provided
valuable information and will help the District with compliance.
Finding 2023-003: Reporting (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible
students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11,
215.10, and 225.15(c)). Each month’s claim for reimbursement and all data used in the claims review process must
be maintained on file. Accurate records must be maintained justifying all meals claimed. Failure to maintain such
records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the
period covered by the records in question. Records are required to be retained for a period of three years after
submission of the final Claim for Reimbursement for the fiscal year.
Condition: From August 2022 through January 2023, all meals served were being hand tallied. Only total meals
served were counted and there were no records maintained to document the free/reduced/paid status of the students
receiving meals. At the end of the month, the District was applying an estimated percentage breakout of
free/reduced/paid to the total meal counts, and using this estimate on their monthly CNIPS claim forms. In addition,
the total meals documented on the District tally sheets could not be consistently reconciled to the total meals
claimed for the two months sampled for testing (September 2022 and January 2023). In February 2023, the District
implemented a point of sale system and began tracking meals by Free/reduced/paid status and reconciling system
records to claim forms.
Cause: Due to turnover at the District and changing procedures after COVID, the District experienced a delayed
implementation of their point of sale system and continued tracking total meals by hand like they had done under the
previous COVID flexibility waivers.
Context: Discrepancies were noted for the months of August 2022 through January 2023.
Effect: Meals reported could not be reconciled to total meals served or eligibility status of participating students.
This could cause inaccurately claimed meal counts and inappropriate reimbursement rates based on
free/reduced/paid eligibility.
Questioned Cost: There was insufficient documentation to determine the total meals served or the breakout
between free, reduced, and paid meals, therefore, a questioned cost cannot be calculated. The total child nutrition
funding claimed for the six months in question was $254,604 Federal and $236,725 State.
Recommendation: We recommend that the District continue to utilize a point of sale system and track all meals
served by student eligibility. We further recommend that these records be reconciled against claim forms on a
monthly basis.
Views of Responsible Officials: The District started the 2022-23 school year without a point of sale system in
place. The rollout of a new point of sale system took until January to get up at all sites and therefore created
challenges for the cafeteria staff to keep up with keeping accurate records for meal claims.
The point of sale has been in place at all sites since January 2023 and has not had issues related to tracking meal
participation. The District is prioritizing systems that synchronize with the student information system to ensure
accurate data is shared across all aspects of school operations that get reported through CALPADS.
Finding 2023-004: Procurement (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented
procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the
acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where
the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified
acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as
determined appropriate by the non-Federal entity.
Condition: During our testing of procurement, we sampled three contracts that would qualify as “small purchases.”
The District could not provide evidence that multiple quotes had been obtained prior to selecting any of the three
vendors.
Cause: Due to high turnover at the District, there has been a lack of oversight to ensure all appropriate
documentation is maintained to demonstrate that the District is in compliance with Public Contract Code and that
purchases are awarded after a reasonable number of quotes have been obtained.
Context: Deficiency was noted in all three contracts tested.
Effect: Contracts were awarded without following proper procurement procedures.
Questioned Cost: This resulted in roughly $86,000 awarded in contracts, without following proper procedures.
Recommendation: We recommend that the District train and implement the required federal procurement
procedures to ensure that the District is in compliance.
Views of Responsible Officials: The District is working to ensure that management staff understand the
requirements of federal procurement for our meal program. The cafeteria program also had a Procurement Review
process with CDE staff about its procurement procedures in the 2022-23 school year. This training provided
valuable information and will help the District with compliance.
Finding 2023-003: Reporting (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible
students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11,
215.10, and 225.15(c)). Each month’s claim for reimbursement and all data used in the claims review process must
be maintained on file. Accurate records must be maintained justifying all meals claimed. Failure to maintain such
records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the
period covered by the records in question. Records are required to be retained for a period of three years after
submission of the final Claim for Reimbursement for the fiscal year.
Condition: From August 2022 through January 2023, all meals served were being hand tallied. Only total meals
served were counted and there were no records maintained to document the free/reduced/paid status of the students
receiving meals. At the end of the month, the District was applying an estimated percentage breakout of
free/reduced/paid to the total meal counts, and using this estimate on their monthly CNIPS claim forms. In addition,
the total meals documented on the District tally sheets could not be consistently reconciled to the total meals
claimed for the two months sampled for testing (September 2022 and January 2023). In February 2023, the District
implemented a point of sale system and began tracking meals by Free/reduced/paid status and reconciling system
records to claim forms.
Cause: Due to turnover at the District and changing procedures after COVID, the District experienced a delayed
implementation of their point of sale system and continued tracking total meals by hand like they had done under the
previous COVID flexibility waivers.
Context: Discrepancies were noted for the months of August 2022 through January 2023.
Effect: Meals reported could not be reconciled to total meals served or eligibility status of participating students.
This could cause inaccurately claimed meal counts and inappropriate reimbursement rates based on
free/reduced/paid eligibility.
Questioned Cost: There was insufficient documentation to determine the total meals served or the breakout
between free, reduced, and paid meals, therefore, a questioned cost cannot be calculated. The total child nutrition
funding claimed for the six months in question was $254,604 Federal and $236,725 State.
Recommendation: We recommend that the District continue to utilize a point of sale system and track all meals
served by student eligibility. We further recommend that these records be reconciled against claim forms on a
monthly basis.
Views of Responsible Officials: The District started the 2022-23 school year without a point of sale system in
place. The rollout of a new point of sale system took until January to get up at all sites and therefore created
challenges for the cafeteria staff to keep up with keeping accurate records for meal claims.
The point of sale has been in place at all sites since January 2023 and has not had issues related to tracking meal
participation. The District is prioritizing systems that synchronize with the student information system to ensure
accurate data is shared across all aspects of school operations that get reported through CALPADS.
Finding 2023-004: Procurement (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented
procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the
acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where
the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified
acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as
determined appropriate by the non-Federal entity.
Condition: During our testing of procurement, we sampled three contracts that would qualify as “small purchases.”
The District could not provide evidence that multiple quotes had been obtained prior to selecting any of the three
vendors.
Cause: Due to high turnover at the District, there has been a lack of oversight to ensure all appropriate
documentation is maintained to demonstrate that the District is in compliance with Public Contract Code and that
purchases are awarded after a reasonable number of quotes have been obtained.
Context: Deficiency was noted in all three contracts tested.
Effect: Contracts were awarded without following proper procurement procedures.
Questioned Cost: This resulted in roughly $86,000 awarded in contracts, without following proper procedures.
Recommendation: We recommend that the District train and implement the required federal procurement
procedures to ensure that the District is in compliance.
Views of Responsible Officials: The District is working to ensure that management staff understand the
requirements of federal procurement for our meal program. The cafeteria program also had a Procurement Review
process with CDE staff about its procurement procedures in the 2022-23 school year. This training provided
valuable information and will help the District with compliance.
Finding 2023-003: Reporting (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible
students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11,
215.10, and 225.15(c)). Each month’s claim for reimbursement and all data used in the claims review process must
be maintained on file. Accurate records must be maintained justifying all meals claimed. Failure to maintain such
records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the
period covered by the records in question. Records are required to be retained for a period of three years after
submission of the final Claim for Reimbursement for the fiscal year.
Condition: From August 2022 through January 2023, all meals served were being hand tallied. Only total meals
served were counted and there were no records maintained to document the free/reduced/paid status of the students
receiving meals. At the end of the month, the District was applying an estimated percentage breakout of
free/reduced/paid to the total meal counts, and using this estimate on their monthly CNIPS claim forms. In addition,
the total meals documented on the District tally sheets could not be consistently reconciled to the total meals
claimed for the two months sampled for testing (September 2022 and January 2023). In February 2023, the District
implemented a point of sale system and began tracking meals by Free/reduced/paid status and reconciling system
records to claim forms.
Cause: Due to turnover at the District and changing procedures after COVID, the District experienced a delayed
implementation of their point of sale system and continued tracking total meals by hand like they had done under the
previous COVID flexibility waivers.
Context: Discrepancies were noted for the months of August 2022 through January 2023.
Effect: Meals reported could not be reconciled to total meals served or eligibility status of participating students.
This could cause inaccurately claimed meal counts and inappropriate reimbursement rates based on
free/reduced/paid eligibility.
Questioned Cost: There was insufficient documentation to determine the total meals served or the breakout
between free, reduced, and paid meals, therefore, a questioned cost cannot be calculated. The total child nutrition
funding claimed for the six months in question was $254,604 Federal and $236,725 State.
Recommendation: We recommend that the District continue to utilize a point of sale system and track all meals
served by student eligibility. We further recommend that these records be reconciled against claim forms on a
monthly basis.
Views of Responsible Officials: The District started the 2022-23 school year without a point of sale system in
place. The rollout of a new point of sale system took until January to get up at all sites and therefore created
challenges for the cafeteria staff to keep up with keeping accurate records for meal claims.
The point of sale has been in place at all sites since January 2023 and has not had issues related to tracking meal
participation. The District is prioritizing systems that synchronize with the student information system to ensure
accurate data is shared across all aspects of school operations that get reported through CALPADS.
Finding 2023-004: Procurement (50000)
Assistance Listing # 10.553, 10.555
Federal Awarding Agency: U.S. Department of Agriculture
Pass-through Agency: California Department of Education
Program Title: Child Nutrition Cluster
Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented
procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the
acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where
the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified
acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as
determined appropriate by the non-Federal entity.
Condition: During our testing of procurement, we sampled three contracts that would qualify as “small purchases.”
The District could not provide evidence that multiple quotes had been obtained prior to selecting any of the three
vendors.
Cause: Due to high turnover at the District, there has been a lack of oversight to ensure all appropriate
documentation is maintained to demonstrate that the District is in compliance with Public Contract Code and that
purchases are awarded after a reasonable number of quotes have been obtained.
Context: Deficiency was noted in all three contracts tested.
Effect: Contracts were awarded without following proper procurement procedures.
Questioned Cost: This resulted in roughly $86,000 awarded in contracts, without following proper procedures.
Recommendation: We recommend that the District train and implement the required federal procurement
procedures to ensure that the District is in compliance.
Views of Responsible Officials: The District is working to ensure that management staff understand the
requirements of federal procurement for our meal program. The cafeteria program also had a Procurement Review
process with CDE staff about its procurement procedures in the 2022-23 school year. This training provided
valuable information and will help the District with compliance.