Audit 393391

Criteria or Specific Requirement: Per 2 CFR 200.303 - Internal Controls and the OMB Compliance Supplement: Child Nutrition Cluster, Procurement and Suspension and Debarment - the District is required to have internal controls to ensure vendors utilized in federal programs are not suspended, debarred, or otherwise excluded from participating in covered transactions. Condition: The District, as a subrecipient of federal awards, contracted with multiple vendors, both directly and indirectly through the use of a purchasing cooperative, without verifiying that the vendor was not suspended, debarred, or otherwise excluded from participating in covered transactions. Questioned Costs: This condition resulted in no identified questioned costs. Context: The District does not have internal controls in place to verify that vendors are not suspended or debarred. Effect: Contracts could be made with vendors that are suspended or debarred, resulting in noncompliance with federal regulations. Cause: In the first instance, the District relied upon a purchasing cooperative to verify that the vendor was not suspended or debarred, but this was not done by the cooperative. In the second instance, the District's contract solicitation requested that a return of a quote or bid act as a self-certification that the vendor was not suspended or debarred. The District made purchases from a vendor, even though the vendor did not return a quote or bid to the District. Recommendation: The District should ensure that the purchasing cooperative has procedures in place to verify that vendors are not suspended or debarred. For other contracts in instances where the vendor does not self-certify, the District should use SAM.gov to verify that vendors are not suspended or debarred before entering into the contract. Management's Response: District personnel will ensure that all vendors utilized are not suspended or debarred, whether that be through vendor self-certification or the documented use of SAM.gov

Criteria or Specific Requirement: School food authorities 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)) Condition: The District, as the school food authority, did not establish effective internal controls to ensure that meal claims were accurately prepared and submitted. One individual was responsible for preparing and submitting meal claims, and there is no secondary review of the meal claim before it is submitted. Questioned Costs: None. Context: The known effects of this internal control deficiency extend to all reimbursement claims made for subprograms in the Child Nutrition Cluster. Effect: Meal claims that do not accurately reflect the number of students served for a month could be submitted. Consequently, the District could be over- or under-reimbursed by this program. Cause: The District did not design the job roles of exisiting personnel to require more than one individual to be involved in and responsible for the meal claim preparation and submission process. Recommendation: The District should design the job roles of existing personnel to require one individual to prepare the meal claim and another individual to perform a review of the meal claim in comparison to monthly meal counts prior to the submission of the meal claim. Management's Response: District personnel will perform a secondary review of the meal claims before the are submitted for reimbursement.