Compliance Over Procurement and Suspension and Debarment U.S. Department of Agriculture (USDA) Child Nutrition Cluster ALN 10.555 Criteria: 2 CFR 200.318(a) requires that non-Federal entities use their own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in 2 CFR 200.318 through 200.327. Accordingly, the entity is required to comply with the Louisiana Public Bid Law, LA R.S. 38:2211 et seq., which governs the procurement of goods and services using public funds. Under Louisiana Public Bid Law, purchases meeting applicable bid thresholds must be made by obtaining quotes or through a formal public bid process, as applicable, to ensure that public funds are expended through a transparent, competitive procurement process. Condition: During our testing of Procurement and Suspension and Debarment for the Child Nutrition Cluster, we selected a sample of 5 vendors from a population of 14 vendors utilized during the fiscal year. For one vendor selected, the School Board made purchases totaling $33,000 without obtaining the required competitive bids or quotes in accordance with Louisiana Public Bid Law. Cause: The School Board did not obtain competitive bids or quotes prior to making purchases from the vendor in question, as required under Louisiana Public Bid Law. This condition indicates a deficiency in the School Board’s procurement controls, including the lack of an adequate review process to ensure that purchases meeting applicable bid thresholds are supported by the required quotes or subjected to a formal competitive bid process before a vendor is selected and a commitment is made. Effect: By failing to obtain competitive bids or quotes as required, the School Board cannot demonstrate that the $33,000 in purchases from this vendor represent the best value to the program or that public funds were expended through a fair and open competitive process as required by Louisiana Public Bid Law and 2 CFR 200.318(a). The $33,000 represents known and questioned costs subject to a potential disallowance by the federal awarding agency. Regarding likely questioned costs: our testing covered 5 of 14 vendors (35.7% of the vendor population). The exception was identified within the tested population; however, because procurement noncompliance in this context was vendor-specific rather than transaction-rate-based, the likely questioned costs are limited to the $33,000 associated with the identified vendor. No extrapolation to the untested vendor population has been made, as the noncompliance relates to a discrete procurement decision rather than a systemic per-transaction error. Recommendation: We recommend that management implement a formal procurement review process to ensure that all purchases meeting or exceeding applicable bid thresholds under Louisiana Public Bid Law are supported by the required quotes or subjected to a competitive bid process prior to vendor selection and commitment of funds. Management should develop or strengthen written procurement policies and procedures that clearly identify bid thresholds, required procurement methods, and documentation retention requirements, consistent with 2 CFR 200.318-200.327. Management should also consult with legal counsel and the federal awarding agency regarding the appropriate disposition of the $33,000 in questioned costs identified. Repeat Finding: No. View of Responsible Officials: Prior to purchases being made, the Child Nutrition Program Supervisor will check for suspension and debarment of vendors. The accounts payable accountant will also review for suspension and debarment prior to the payment being made. Evidence of review will be maintained in an appropriately labeled file each year. See response to finding 2025-018 above.
Controls Over Procurement and Suspension and Debarment U.S. Department of Agriculture (USDA) Child Nutrition Cluster ALN 10.555 Criteria: 2 CFR 200.318(a) requires that non-Federal entities use their own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in 2 CFR 200.318 through 200.327. The entity is also required to maintain procurement records sufficient to document the history of each procurement transaction, including the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: During our testing of procurement and suspension and debarment for the Child Nutrition Cluster, we selected a sample of 5 vendors/contracts from a population of 14 vendors utilized during the fiscal year. For one vendor selected, the School Board was unable to provide a complete contract file containing evidence that the contract terms were properly reviewed and/or approved prior to execution. The file also did not contain sufficient documentation to demonstrate that the procurement file was complete and reviewed for compliance with applicable procurement and suspension and debarment requirements. Cause: The School Board had policies and procedures in place to ensure contract files included required documentation, including evidence of review and approval of contract terms. However, the policies and procedures were not consistently followed. As a result, the contract file did not contain sufficient documentation to demonstrate that the required review and approval procedures were performed. Effect: Without a complete contract file, the School Board cannot demonstrate that the contract terms were properly reviewed and approved, that the procurement was complete in accordance with applicable requirements, or that suspension and debarment procedures were adequately documented. This increases the risk that federally funded contracts may be awarded to vendors that are suspended, debarred, or otherwise excluded from participation in federal programs. Recommendation: We recommend that management strengthen the application of its existing procurement and contract review procedures to ensure they are consistently followed for all federally funded purchases. Contract files should be reviewed for completeness prior to contract execution and payment to ensure they include evidence of contract term review and approval, procurement support, and suspension and debarment verification. We also recommend that management periodically monitor contract files for compliance with established policies and procedures. Repeat Finding: No. View of Responsible Officials: Prior to purchases being made, the Child Nutrition Program Supervisor will check for suspension and debarment of vendors. The accounts payable accountant will also review for suspension and debarment prior to payment being made. Evidence of review will be maintained in an appropriately labeled file each year.
Compliance Over Allowable Costs/Activities Allowed U.S. Department of Education Title I ALN 84.010 Criteria: 2 CFR 200.405, costs must be allocable to a federal award. A cost is allocable if it is assignable to the award in accordance with the relative benefits received. Costs that benefit another program or activity may not be charged to a federal award. Additionally, the award agreement governing Title I requires that reimbursement requests be supported by adequate documentation evidencing that costs claimed are allowable, allocable, and in compliance with the terms and conditions of the federal award. Per 2 CFR 200.403, costs must be adequately documented to be allowable under federal awards. Condition: During our testing of Allowable Costs and Activities Allowed for Title I, we selected a sample of 77 transactions from the program’s population of expenditures for the year ended June 30, 2025. Of the 77 transactions tested, 2 exceptions were identified. For one transaction selected, professional service costs totaling $6,400 were charged to Title I that were incurred for and should have been charged to a separate, unrelated federal program. These costs do not benefit Title I and are therefore unallowable charges to this award. For one transaction selected, the School Board was unable to provide a reimbursement request to support costs of $1,350 claimed under the program. Cause: The $6,400 cross-charge of professional services costs appears to result from an error in cost allocation or coding, in which expenditures incurred for another program were incorrectly assigned to Title I. This indicates a deficiency in the School Board’s controls over the allocation of costs across federal programs. The unsupported reimbursement request of $1,350 indicates a deficiency in controls over the retention of supporting documentation for costs charged to the program. Effect: The misallocation of $6,400 in professional services costs to Title I resulted in unallowable costs being charged to the award. These costs provided no benefit to Title I and may be subject to disallowance by the federal awarding agency. The unsupported reimbursement request of $1,350 similarly represents a cost for which compliance with award requirements cannot be demonstrated. In aggregate, the 2 exceptions represent $7,750 in known questioned costs. Projecting the identified error rate of 2.6% (2 exceptions out of 77 transactions tested) to the full program population results in approximately $80,900 in likely questioned costs. Recommendation: We recommend that management strengthen controls over the allocation of costs to federal award programs to ensure that expenditures are charged only to the award that received the benefit of those costs, consistent with 2 CFR 200.405. Specifically, management should implement a review process to verify the accuracy of program costs coding prior to submission of reimbursement requests. Management should also refund or reclassify the $6,400 in professional service costs that were incorrectly charged to Title I. Additionally, management should implement controls to ensure that all reimbursement requests are supported by adequate documentation retained and available for audit. Repeat Finding: No. View of Responsible Officials: Beginning with FY2026, a new Federal Programs Supervisor/Director was hired by the Board, and a Fiscal Administrator was appointed on August 27, 2025. These new designees will ensure that all federal programs operate within their allowable costs, activities, procurement, suspension and debarment guidelines. Approved budgets will be reviewed and complied with as purchases are made and reviewed monthly thereafter.
Compliance Over Allowable Costs/Activities Allowed U.S. Department of Education Education Stabilization Fund ALN 84.425 Criteria: The award agreement governing ESSER requires that the School Board submit reimbursement requests supported by adequate documentation evidencing that costs claimed are allowed, allocable, and in compliance with terms and conditions of the federal award. Per 2 CFR 200.403, costs must be adequately documented to be allowable under federal awards. Condition: During our testing of Allowable Costs and Activities Allowed, we selected a sample of 77 transactions from ESSER’s population of expenditures for the year ended June 30, 2025. Of the 77 transactions, 2 instances were identified in which the School Board was unable to provide reimbursement requests to support the costs claimed under the program. The total dollar value of the unsupported transactions is $21,000. Cause: The School Board did not maintain adequate controls over the retention and organization of reimbursement request documentation supporting costs charged to the program. As a result, documentation necessary to demonstrate compliance with the award agreement’s reimbursement request requirements could not be located or provided to the auditors upon request. Effect: Without adequate documentation supporting reimbursement requests, the School Board cannot demonstrate that costs charged to ESSER are allowable under the terms and conditions of the federal award. This creates a risk that unallowable costs have been or may be claimed for federal reimbursement. The 2 unsupported transactions represent $21,000 in known questioned costs. Projecting the identified error rate of 2.6% (2 exceptions out of 77 transactions tested) to full program population results in approximately $63,000 in likely questioned costs, which may be subject to disallowance by the federal awarding agency. Recommendation: We recommend that management implement controls to ensure that all reimbursement requests submitted under federal award programs are retained in an organized manner and made readily available for audit. Management should also review the two reimbursement requests that could not be provided and attempt to obtain copies from internal records, the grant portal, or the applicable grantor/passthrough agency. If the reimbursement requests cannot be located, management should evaluate whether additional communication with the grantor or passthrough agency is necessary. Repeat Finding: No. View of Responsible Officials: Beginning with FY2026, a new Federal Programs Supervisor/Director was hired by the Board, and a Fiscal Administrator was appointed on August 27, 2025. These new designees will ensure that all federal programs operate within their allowable costs, activities, procurement, suspension and debarment guidelines. Approved budgets will be reviewed and complie with as purchases are made and reviewed monthly thereafter.
Controls Over Allowable Cost/Activities Allowed U.S. Department of Education Education Stabilization Fund ALN 84.425 Title I ALN 84.010 Criteria: Uniform Guidance (2 CFR Part 200) requires that costs charged to federal awards be allowable, reasonable, and properly authorized, and that nonfederal entities establish effective internal controls over federal awards to provide reasonable assurance of compliance with federal requirements. Costs charged to Education Stabilization Fund (ESSER) and Title I grants should be supported by appropriate documentation and approved to ensure the activities performed are allowable under the respective grant programs. Condition: During our testing of internal controls over allowable costs and activities related to expenses charged to ESSER and Title I grants, we noted that controls over the approval were not operating effectively. Specifically, charges to these grant programs were not consistently supported by documented supervisory approval verifying that the employees’ activities and services performed or good provided were allowable and aligned with the objectives of the respective grants. Cause: This condition was caused by the lack of formalized approval procedures over grant-funded costs and insufficient documentation requirements to demonstrate management’s review of allowability and programmatic alignment. Effect: Without adequate approval controls over costs charged to ESSER and Title I grants, the School Board is exposed to an increased risk that unallowable or unsupported costs could be charged to federal programs. This may result in questioned costs, required repayment of grant funds, or increased oversight by federal or state granting agencies. Recommendation: We recommend that management implement formal approval and documentation procedures for all costs charged to ESSER and Title I grants. Such procedures should include documented supervisory review verifying that charges are allowable, reasonable, and directly related to approved grant activities prior to charging costs to the grant. Repeat Finding: Yes. 2024-020 View of Responsible Officials: Beginning with FY2026, a new Federal Programs Supervisor/Director was hired by the Board, and a Fiscal Administrator was appointed on August 27, 2025. These new designees will ensure that all federal programs operate within their allowable costs, activities, procurement, suspension and debarment guidelines. Approved budgets will be reviewed and complied with as purchases are made and reviewed monthly thereafter.