2023-003 Procurement, Suspension and Debarment
U.S. Department of Education/Pass-through Texas Department of Agriculture
Federal Assistance Listing Number 10.568 – Emergency Food Assistance Program (Administrative Costs)
Award Numbers: TX-101-7058 and 01534
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.187 – Commodity Credit Corporation (Administrative Costs)
Award Number: 01534
Aware Year: 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.565 – Commodity Supplemental Food Program (Administrative Costs)
Award Number: TX-101-4001
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for internal controls over compliance with Procurement, Suspension, and
Debarment in accordance with the Uniform Guidance.
Condition: Management has a procurement policy in place to ensure compliance with federal law and
standards. However, one vendor’s contract was renewed without a formal bidding process and verification of
suspension and debarment as required according to the procurement policy.
Questioned Costs: None
Context/Sampling: A nonstatistical sample of 3 out of 14 vendors were selected for testing.
Cause: During the time the vendor was due for renewal, there was turnover of the CFO. Therefore, The Food
Bank did not allocate enough time and resources to properly prepare a bidding process.
Effect or potential effect: Lack of compliance with Procurement, Suspension, and Debarment compliance
requirement may result in reduced future funding for the program.
Recommendation: We recommend The Food Bank incorporate controls and procedures to ensure the
Procurement Policy is being adhered to at all times.
Views of Responsible Officials: The Food Bank agrees with the finding. Due to turnover and transitions in
key positions during the COVID-19 pandemic, a contract agreement was renewed with Houston Food Bank’s
benefits broker without a formal bidding process.
Corrective Actions: In FY 2024 vendor analysis by the Procurement department has been completed and
communicated to each director to create an RFP schedule for all contract renewals. Annual education of
directors and managers on the procurement policy, informal bid, and formal bid processes was completed in
June 2023.
2023-003 Procurement, Suspension and Debarment
U.S. Department of Education/Pass-through Texas Department of Agriculture
Federal Assistance Listing Number 10.568 – Emergency Food Assistance Program (Administrative Costs)
Award Numbers: TX-101-7058 and 01534
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.187 – Commodity Credit Corporation (Administrative Costs)
Award Number: 01534
Aware Year: 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.565 – Commodity Supplemental Food Program (Administrative Costs)
Award Number: TX-101-4001
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for internal controls over compliance with Procurement, Suspension, and
Debarment in accordance with the Uniform Guidance.
Condition: Management has a procurement policy in place to ensure compliance with federal law and
standards. However, one vendor’s contract was renewed without a formal bidding process and verification of
suspension and debarment as required according to the procurement policy.
Questioned Costs: None
Context/Sampling: A nonstatistical sample of 3 out of 14 vendors were selected for testing.
Cause: During the time the vendor was due for renewal, there was turnover of the CFO. Therefore, The Food
Bank did not allocate enough time and resources to properly prepare a bidding process.
Effect or potential effect: Lack of compliance with Procurement, Suspension, and Debarment compliance
requirement may result in reduced future funding for the program.
Recommendation: We recommend The Food Bank incorporate controls and procedures to ensure the
Procurement Policy is being adhered to at all times.
Views of Responsible Officials: The Food Bank agrees with the finding. Due to turnover and transitions in
key positions during the COVID-19 pandemic, a contract agreement was renewed with Houston Food Bank’s
benefits broker without a formal bidding process.
Corrective Actions: In FY 2024 vendor analysis by the Procurement department has been completed and
communicated to each director to create an RFP schedule for all contract renewals. Annual education of
directors and managers on the procurement policy, informal bid, and formal bid processes was completed in
June 2023.
2023-003 Procurement, Suspension and Debarment
U.S. Department of Education/Pass-through Texas Department of Agriculture
Federal Assistance Listing Number 10.568 – Emergency Food Assistance Program (Administrative Costs)
Award Numbers: TX-101-7058 and 01534
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.187 – Commodity Credit Corporation (Administrative Costs)
Award Number: 01534
Aware Year: 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.565 – Commodity Supplemental Food Program (Administrative Costs)
Award Number: TX-101-4001
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for internal controls over compliance with Procurement, Suspension, and
Debarment in accordance with the Uniform Guidance.
Condition: Management has a procurement policy in place to ensure compliance with federal law and
standards. However, one vendor’s contract was renewed without a formal bidding process and verification of
suspension and debarment as required according to the procurement policy.
Questioned Costs: None
Context/Sampling: A nonstatistical sample of 3 out of 14 vendors were selected for testing.
Cause: During the time the vendor was due for renewal, there was turnover of the CFO. Therefore, The Food
Bank did not allocate enough time and resources to properly prepare a bidding process.
Effect or potential effect: Lack of compliance with Procurement, Suspension, and Debarment compliance
requirement may result in reduced future funding for the program.
Recommendation: We recommend The Food Bank incorporate controls and procedures to ensure the
Procurement Policy is being adhered to at all times.
Views of Responsible Officials: The Food Bank agrees with the finding. Due to turnover and transitions in
key positions during the COVID-19 pandemic, a contract agreement was renewed with Houston Food Bank’s
benefits broker without a formal bidding process.
Corrective Actions: In FY 2024 vendor analysis by the Procurement department has been completed and
communicated to each director to create an RFP schedule for all contract renewals. Annual education of
directors and managers on the procurement policy, informal bid, and formal bid processes was completed in
June 2023.
2023-004 Eligibility
U.S. Department of Education/Pass-through Texas Department of Agriculture
Federal Assistance Listing Number 10.187 – Commodity Credit Corporation
Award Number: 01534
Award Year: 10/1/22 – 9/30/23
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for compliance with Eligibility procedures in accordance with
the Uniform Guidance.
Condition: One of the subrecipients’ (i.e. , Agencies receiving food for distribution) eligibility
requirements is for The Food Bank to conduct annual site visits to verify the site’s ability to operate
in full compliance with the requirements of the agency agreement. Three subrecipients tested did
not have evidence of an annual site visit.
Questioned Costs: None
Context/Sampling: A nonstatistical sample of 21 out of 209 subrecipients was selected for
testing.
Cause: The Food Bank experienced significant turnover in the Partner Services Department
resulting in these annual visits being missed during 2023.
Effect or Potential Effect: Lack of compliance with Eligibility compliance requirements may result
in reduced future funding for the program.
Recommendation: We recommend The Food Bank incorporate controls and procedures to
ensure the subrecipient eligibility requirements are being followed.
Views of Responsible Officials: The Food Bank agrees with the finding. Due to turnover and transitions in key positions, on-boarding of agencies did not include these three locations on the annual site visit schedule.
Corrective Actions: In FY 2024 new procedures have already been implemented for on-boarding, new personnel have been assigned oversight of agencies, and two compliance departments, one in Accounting and one in Partner Services, have been fully established to monitor compliance.
2023-003 Procurement, Suspension and Debarment
U.S. Department of Education/Pass-through Texas Department of Agriculture
Federal Assistance Listing Number 10.568 – Emergency Food Assistance Program (Administrative Costs)
Award Numbers: TX-101-7058 and 01534
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.187 – Commodity Credit Corporation (Administrative Costs)
Award Number: 01534
Aware Year: 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.565 – Commodity Supplemental Food Program (Administrative Costs)
Award Number: TX-101-4001
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for internal controls over compliance with Procurement, Suspension, and
Debarment in accordance with the Uniform Guidance.
Condition: Management has a procurement policy in place to ensure compliance with federal law and
standards. However, one vendor’s contract was renewed without a formal bidding process and verification of
suspension and debarment as required according to the procurement policy.
Questioned Costs: None
Context/Sampling: A nonstatistical sample of 3 out of 14 vendors were selected for testing.
Cause: During the time the vendor was due for renewal, there was turnover of the CFO. Therefore, The Food
Bank did not allocate enough time and resources to properly prepare a bidding process.
Effect or potential effect: Lack of compliance with Procurement, Suspension, and Debarment compliance
requirement may result in reduced future funding for the program.
Recommendation: We recommend The Food Bank incorporate controls and procedures to ensure the
Procurement Policy is being adhered to at all times.
Views of Responsible Officials: The Food Bank agrees with the finding. Due to turnover and transitions in
key positions during the COVID-19 pandemic, a contract agreement was renewed with Houston Food Bank’s
benefits broker without a formal bidding process.
Corrective Actions: In FY 2024 vendor analysis by the Procurement department has been completed and
communicated to each director to create an RFP schedule for all contract renewals. Annual education of
directors and managers on the procurement policy, informal bid, and formal bid processes was completed in
June 2023.
2023-003 Procurement, Suspension and Debarment
U.S. Department of Education/Pass-through Texas Department of Agriculture
Federal Assistance Listing Number 10.568 – Emergency Food Assistance Program (Administrative Costs)
Award Numbers: TX-101-7058 and 01534
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.187 – Commodity Credit Corporation (Administrative Costs)
Award Number: 01534
Aware Year: 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.565 – Commodity Supplemental Food Program (Administrative Costs)
Award Number: TX-101-4001
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for internal controls over compliance with Procurement, Suspension, and
Debarment in accordance with the Uniform Guidance.
Condition: Management has a procurement policy in place to ensure compliance with federal law and
standards. However, one vendor’s contract was renewed without a formal bidding process and verification of
suspension and debarment as required according to the procurement policy.
Questioned Costs: None
Context/Sampling: A nonstatistical sample of 3 out of 14 vendors were selected for testing.
Cause: During the time the vendor was due for renewal, there was turnover of the CFO. Therefore, The Food
Bank did not allocate enough time and resources to properly prepare a bidding process.
Effect or potential effect: Lack of compliance with Procurement, Suspension, and Debarment compliance
requirement may result in reduced future funding for the program.
Recommendation: We recommend The Food Bank incorporate controls and procedures to ensure the
Procurement Policy is being adhered to at all times.
Views of Responsible Officials: The Food Bank agrees with the finding. Due to turnover and transitions in
key positions during the COVID-19 pandemic, a contract agreement was renewed with Houston Food Bank’s
benefits broker without a formal bidding process.
Corrective Actions: In FY 2024 vendor analysis by the Procurement department has been completed and
communicated to each director to create an RFP schedule for all contract renewals. Annual education of
directors and managers on the procurement policy, informal bid, and formal bid processes was completed in
June 2023.
2023-003 Procurement, Suspension and Debarment
U.S. Department of Education/Pass-through Texas Department of Agriculture
Federal Assistance Listing Number 10.568 – Emergency Food Assistance Program (Administrative Costs)
Award Numbers: TX-101-7058 and 01534
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.187 – Commodity Credit Corporation (Administrative Costs)
Award Number: 01534
Aware Year: 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.565 – Commodity Supplemental Food Program (Administrative Costs)
Award Number: TX-101-4001
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for internal controls over compliance with Procurement, Suspension, and
Debarment in accordance with the Uniform Guidance.
Condition: Management has a procurement policy in place to ensure compliance with federal law and
standards. However, one vendor’s contract was renewed without a formal bidding process and verification of
suspension and debarment as required according to the procurement policy.
Questioned Costs: None
Context/Sampling: A nonstatistical sample of 3 out of 14 vendors were selected for testing.
Cause: During the time the vendor was due for renewal, there was turnover of the CFO. Therefore, The Food
Bank did not allocate enough time and resources to properly prepare a bidding process.
Effect or potential effect: Lack of compliance with Procurement, Suspension, and Debarment compliance
requirement may result in reduced future funding for the program.
Recommendation: We recommend The Food Bank incorporate controls and procedures to ensure the
Procurement Policy is being adhered to at all times.
Views of Responsible Officials: The Food Bank agrees with the finding. Due to turnover and transitions in
key positions during the COVID-19 pandemic, a contract agreement was renewed with Houston Food Bank’s
benefits broker without a formal bidding process.
Corrective Actions: In FY 2024 vendor analysis by the Procurement department has been completed and
communicated to each director to create an RFP schedule for all contract renewals. Annual education of
directors and managers on the procurement policy, informal bid, and formal bid processes was completed in
June 2023.
2023-003 Procurement, Suspension and Debarment
U.S. Department of Education/Pass-through Texas Department of Agriculture
Federal Assistance Listing Number 10.568 – Emergency Food Assistance Program (Administrative Costs)
Award Numbers: TX-101-7058 and 01534
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.187 – Commodity Credit Corporation (Administrative Costs)
Award Number: 01534
Aware Year: 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.565 – Commodity Supplemental Food Program (Administrative Costs)
Award Number: TX-101-4001
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for internal controls over compliance with Procurement, Suspension, and
Debarment in accordance with the Uniform Guidance.
Condition: Management has a procurement policy in place to ensure compliance with federal law and
standards. However, one vendor’s contract was renewed without a formal bidding process and verification of
suspension and debarment as required according to the procurement policy.
Questioned Costs: None
Context/Sampling: A nonstatistical sample of 3 out of 14 vendors were selected for testing.
Cause: During the time the vendor was due for renewal, there was turnover of the CFO. Therefore, The Food
Bank did not allocate enough time and resources to properly prepare a bidding process.
Effect or potential effect: Lack of compliance with Procurement, Suspension, and Debarment compliance
requirement may result in reduced future funding for the program.
Recommendation: We recommend The Food Bank incorporate controls and procedures to ensure the
Procurement Policy is being adhered to at all times.
Views of Responsible Officials: The Food Bank agrees with the finding. Due to turnover and transitions in
key positions during the COVID-19 pandemic, a contract agreement was renewed with Houston Food Bank’s
benefits broker without a formal bidding process.
Corrective Actions: In FY 2024 vendor analysis by the Procurement department has been completed and
communicated to each director to create an RFP schedule for all contract renewals. Annual education of
directors and managers on the procurement policy, informal bid, and formal bid processes was completed in
June 2023.
2023-004 Eligibility
U.S. Department of Education/Pass-through Texas Department of Agriculture
Federal Assistance Listing Number 10.187 – Commodity Credit Corporation
Award Number: 01534
Award Year: 10/1/22 – 9/30/23
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for compliance with Eligibility procedures in accordance with
the Uniform Guidance.
Condition: One of the subrecipients’ (i.e. , Agencies receiving food for distribution) eligibility
requirements is for The Food Bank to conduct annual site visits to verify the site’s ability to operate
in full compliance with the requirements of the agency agreement. Three subrecipients tested did
not have evidence of an annual site visit.
Questioned Costs: None
Context/Sampling: A nonstatistical sample of 21 out of 209 subrecipients was selected for
testing.
Cause: The Food Bank experienced significant turnover in the Partner Services Department
resulting in these annual visits being missed during 2023.
Effect or Potential Effect: Lack of compliance with Eligibility compliance requirements may result
in reduced future funding for the program.
Recommendation: We recommend The Food Bank incorporate controls and procedures to
ensure the subrecipient eligibility requirements are being followed.
Views of Responsible Officials: The Food Bank agrees with the finding. Due to turnover and transitions in key positions, on-boarding of agencies did not include these three locations on the annual site visit schedule.
Corrective Actions: In FY 2024 new procedures have already been implemented for on-boarding, new personnel have been assigned oversight of agencies, and two compliance departments, one in Accounting and one in Partner Services, have been fully established to monitor compliance.
2023-003 Procurement, Suspension and Debarment
U.S. Department of Education/Pass-through Texas Department of Agriculture
Federal Assistance Listing Number 10.568 – Emergency Food Assistance Program (Administrative Costs)
Award Numbers: TX-101-7058 and 01534
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.187 – Commodity Credit Corporation (Administrative Costs)
Award Number: 01534
Aware Year: 10/1/22 – 9/30/23
Federal Assistance Listing Number 10.565 – Commodity Supplemental Food Program (Administrative Costs)
Award Number: TX-101-4001
Award Years: 10/1/21 – 9/30/22 and 10/1/22 – 9/30/23
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for internal controls over compliance with Procurement, Suspension, and
Debarment in accordance with the Uniform Guidance.
Condition: Management has a procurement policy in place to ensure compliance with federal law and
standards. However, one vendor’s contract was renewed without a formal bidding process and verification of
suspension and debarment as required according to the procurement policy.
Questioned Costs: None
Context/Sampling: A nonstatistical sample of 3 out of 14 vendors were selected for testing.
Cause: During the time the vendor was due for renewal, there was turnover of the CFO. Therefore, The Food
Bank did not allocate enough time and resources to properly prepare a bidding process.
Effect or potential effect: Lack of compliance with Procurement, Suspension, and Debarment compliance
requirement may result in reduced future funding for the program.
Recommendation: We recommend The Food Bank incorporate controls and procedures to ensure the
Procurement Policy is being adhered to at all times.
Views of Responsible Officials: The Food Bank agrees with the finding. Due to turnover and transitions in
key positions during the COVID-19 pandemic, a contract agreement was renewed with Houston Food Bank’s
benefits broker without a formal bidding process.
Corrective Actions: In FY 2024 vendor analysis by the Procurement department has been completed and
communicated to each director to create an RFP schedule for all contract renewals. Annual education of
directors and managers on the procurement policy, informal bid, and formal bid processes was completed in
June 2023.