Audit 395713

Criteria or specific requirement: The Code of Federal Regulations (CFR) Title 2, part 180.220 states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. Condition: The District did not obtain debarment certification or document their vendor search in the System for Award Management website for vendors contracted in excess of $25,000 related to the grant program. Upon further review, it was determined that the vendors were not suspended or debarred. Questioned costs: None. Context: The District did not document their verification that selected vendors were not suspended or debarred. Effect: Noncompliance with the federal award program's suspension and debarment compliance requirements could occur and not be detected and corrected timely. Cause: Written procedures are not in place to verify if vendors contracted in excess of $25,000 related to the Child Nutrition Cluster program are not suspended, debarred, or otherwise excluded from doing business. Recommendation: Procedures need to be implemented to ensure all vendors contracted with have not been suspended or debarred or otherwise excluded from doing business, prior to procuring their services. Management's response: The District did verify vendors on the System of Award Management website, but lack written documentation. In the future, ISBE Form 85-34 will be completed in all future bid packets.

Criteria or Specific Requirement: Per 2 CFR 200.303 - Internal Controls and the OMB Complaince Supplement: Child Nutrition Cluster, Reporting - The District is required to have internal controls, including segregation of duties, over reporting of monthly reimbursement claims. Condition: The same individiual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval before submission. Questioned Costs: The condition has resulted in no identified questioned costs. Context: Currently one individual is responsible for preparing and submitting the monthly reimbursement claims. Effect: Meal claims could be submitted to the Illinois State Board of Education that do not accurately reflect the number of meals served. Consequently, the District could be over- or under-reimbursed by this program. Cause: Abscense of formal internal control procedures resulted in one person performing all reporting functions. Recomendation: Implement segregation of duties by requiring one person to prepare the monthly claim and a second person (e.g., supervisor) to review and approve the claim before submission. The review should be suppported with signatures or electronic approval logs. Management's Reponse: A corrective action plan will be developed and implemented. A secondary review of the meal claim to the supporting documents will be performed before the meal claim is submitted.