Audit 373952

Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Supply Chain, noncash assistance, Summer Food Service Program Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. U.S. Department of Education Special Education Cluster (Special Education – Grants to States and Special Education – Preschool Grants Assistance Listing Numbers 84.027 and 84.173) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Additionally, we noted that there was no verification that procurements through state contracts were invoiced to the District at the contract rates. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. The District could also be overpaying for goods. Questioned Costs: None Perspective Information: A review of vendors charged to the major programs determined no vendors were suspended or debarred. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Additionally, we recommend that a review of invoices as compared to bidding/contracting documentation be performed prior to payment. Views of responsible officials and planned corrective actions: Effective July 1, 2025 the Executive Director of Business & Human Resources, Kevin J. Polunci will review and and verify the eligibility of vendors that participate in federal assistance programs and on an annual basis. Additionally, the District will review the eligibility of potential vendors that participate in federal assistance programs and compare invoices to bidding/contracts prior to payments.