The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. See Schedule of Findings and Questioned Costs for chart/table Background During fiscal year 2022, the District received $902,446 in federal funds for the School Breakfast Program, National School Lunch Program and Summer Food Service Program for Children. These programs provide funding for free and reduced-price meals for eligible students whose households meet specific income requirements set by the U.S. Department of Agriculture. Federal regulations require recipients to establish and maintain internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Federal requirements prohibit grant recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever a government enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify that the contractors have not been suspended, debarred or otherwise excluded. The District may accomplish this verification by obtaining a written certification from the contractor, inserting a clause or condition into the contract that states the contractor is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration?s System for Award Management at SAM.gov. The District must perform this verification before entering into the contract or before charging the costs to a federal award. Description of Condition The District?s controls were inadequate for ensuring that it verified all parties receiving $25,000 or more in federal funds were not suspended or debarred. The District did not obtain a written certification, include a clause in the contract, or search for exclusion records in SAM.gov to verify one of its two contractors subject to this requirement was not suspended or debarred. During fiscal year 2022, the District used $59,756 of program funds to pay this contractor for food services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District approved a contract for food services with a vendor who subsequently subcontracted the bid to another vendor. The District paid the subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. Effect of Condition Without adequate internal controls, the District cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any program funds the District used to pay a contractor that has been suspended or debarred would be unallowable, and the federal grantor could potentially recover them. We verified the contractor was not suspended or debarred, so we are not questioning costs. Recommendation We recommend the District strengthen its internal controls to ensure that all contractors paid $25,000 or more, all or in part with federal funds, are not suspended or debarred before entering into contracts with them or charging their costs to the federal programs. District?s Response It was stated that the District paid a subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. The District however does know that a verification needs to happen, but when the change happened in FY 2022, that was the same year of several staffing changes. The documents requested were difficult to locate as the Director of Finance at the time had retired and the Districts Food Service Director is currently out on a leave of absence. A suspension and debarment verification was provided for the audit, however it was not allowed as it did not reflect a print date. Moving forward, the District will ensure that all verifications have a date, with all documentation to be filed with the Director of Finance. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, 0MB Guidelines to Agencies on Government wide Debarment and Suspension (Nonprocurement) establishes non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. See Schedule of Findings and Questioned Costs for chart/table Background During fiscal year 2022, the District received $902,446 in federal funds for the School Breakfast Program, National School Lunch Program and Summer Food Service Program for Children. These programs provide funding for free and reduced-price meals for eligible students whose households meet specific income requirements set by the U.S. Department of Agriculture. Federal regulations require recipients to establish and maintain internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Federal requirements prohibit grant recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever a government enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify that the contractors have not been suspended, debarred or otherwise excluded. The District may accomplish this verification by obtaining a written certification from the contractor, inserting a clause or condition into the contract that states the contractor is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration?s System for Award Management at SAM.gov. The District must perform this verification before entering into the contract or before charging the costs to a federal award. Description of Condition The District?s controls were inadequate for ensuring that it verified all parties receiving $25,000 or more in federal funds were not suspended or debarred. The District did not obtain a written certification, include a clause in the contract, or search for exclusion records in SAM.gov to verify one of its two contractors subject to this requirement was not suspended or debarred. During fiscal year 2022, the District used $59,756 of program funds to pay this contractor for food services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District approved a contract for food services with a vendor who subsequently subcontracted the bid to another vendor. The District paid the subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. Effect of Condition Without adequate internal controls, the District cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any program funds the District used to pay a contractor that has been suspended or debarred would be unallowable, and the federal grantor could potentially recover them. We verified the contractor was not suspended or debarred, so we are not questioning costs. Recommendation We recommend the District strengthen its internal controls to ensure that all contractors paid $25,000 or more, all or in part with federal funds, are not suspended or debarred before entering into contracts with them or charging their costs to the federal programs. District?s Response It was stated that the District paid a subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. The District however does know that a verification needs to happen, but when the change happened in FY 2022, that was the same year of several staffing changes. The documents requested were difficult to locate as the Director of Finance at the time had retired and the Districts Food Service Director is currently out on a leave of absence. A suspension and debarment verification was provided for the audit, however it was not allowed as it did not reflect a print date. Moving forward, the District will ensure that all verifications have a date, with all documentation to be filed with the Director of Finance. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, 0MB Guidelines to Agencies on Government wide Debarment and Suspension (Nonprocurement) establishes non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. See Schedule of Findings and Questioned Costs for chart/table Background During fiscal year 2022, the District received $902,446 in federal funds for the School Breakfast Program, National School Lunch Program and Summer Food Service Program for Children. These programs provide funding for free and reduced-price meals for eligible students whose households meet specific income requirements set by the U.S. Department of Agriculture. Federal regulations require recipients to establish and maintain internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Federal requirements prohibit grant recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever a government enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify that the contractors have not been suspended, debarred or otherwise excluded. The District may accomplish this verification by obtaining a written certification from the contractor, inserting a clause or condition into the contract that states the contractor is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration?s System for Award Management at SAM.gov. The District must perform this verification before entering into the contract or before charging the costs to a federal award. Description of Condition The District?s controls were inadequate for ensuring that it verified all parties receiving $25,000 or more in federal funds were not suspended or debarred. The District did not obtain a written certification, include a clause in the contract, or search for exclusion records in SAM.gov to verify one of its two contractors subject to this requirement was not suspended or debarred. During fiscal year 2022, the District used $59,756 of program funds to pay this contractor for food services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District approved a contract for food services with a vendor who subsequently subcontracted the bid to another vendor. The District paid the subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. Effect of Condition Without adequate internal controls, the District cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any program funds the District used to pay a contractor that has been suspended or debarred would be unallowable, and the federal grantor could potentially recover them. We verified the contractor was not suspended or debarred, so we are not questioning costs. Recommendation We recommend the District strengthen its internal controls to ensure that all contractors paid $25,000 or more, all or in part with federal funds, are not suspended or debarred before entering into contracts with them or charging their costs to the federal programs. District?s Response It was stated that the District paid a subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. The District however does know that a verification needs to happen, but when the change happened in FY 2022, that was the same year of several staffing changes. The documents requested were difficult to locate as the Director of Finance at the time had retired and the Districts Food Service Director is currently out on a leave of absence. A suspension and debarment verification was provided for the audit, however it was not allowed as it did not reflect a print date. Moving forward, the District will ensure that all verifications have a date, with all documentation to be filed with the Director of Finance. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, 0MB Guidelines to Agencies on Government wide Debarment and Suspension (Nonprocurement) establishes non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. See Schedule of Findings and Questioned Costs for chart/table Background During fiscal year 2022, the District received $902,446 in federal funds for the School Breakfast Program, National School Lunch Program and Summer Food Service Program for Children. These programs provide funding for free and reduced-price meals for eligible students whose households meet specific income requirements set by the U.S. Department of Agriculture. Federal regulations require recipients to establish and maintain internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Federal requirements prohibit grant recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever a government enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify that the contractors have not been suspended, debarred or otherwise excluded. The District may accomplish this verification by obtaining a written certification from the contractor, inserting a clause or condition into the contract that states the contractor is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration?s System for Award Management at SAM.gov. The District must perform this verification before entering into the contract or before charging the costs to a federal award. Description of Condition The District?s controls were inadequate for ensuring that it verified all parties receiving $25,000 or more in federal funds were not suspended or debarred. The District did not obtain a written certification, include a clause in the contract, or search for exclusion records in SAM.gov to verify one of its two contractors subject to this requirement was not suspended or debarred. During fiscal year 2022, the District used $59,756 of program funds to pay this contractor for food services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District approved a contract for food services with a vendor who subsequently subcontracted the bid to another vendor. The District paid the subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. Effect of Condition Without adequate internal controls, the District cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any program funds the District used to pay a contractor that has been suspended or debarred would be unallowable, and the federal grantor could potentially recover them. We verified the contractor was not suspended or debarred, so we are not questioning costs. Recommendation We recommend the District strengthen its internal controls to ensure that all contractors paid $25,000 or more, all or in part with federal funds, are not suspended or debarred before entering into contracts with them or charging their costs to the federal programs. District?s Response It was stated that the District paid a subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. The District however does know that a verification needs to happen, but when the change happened in FY 2022, that was the same year of several staffing changes. The documents requested were difficult to locate as the Director of Finance at the time had retired and the Districts Food Service Director is currently out on a leave of absence. A suspension and debarment verification was provided for the audit, however it was not allowed as it did not reflect a print date. Moving forward, the District will ensure that all verifications have a date, with all documentation to be filed with the Director of Finance. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, 0MB Guidelines to Agencies on Government wide Debarment and Suspension (Nonprocurement) establishes non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. See Schedule of Findings and Questioned Costs for chart/table Background During fiscal year 2022, the District received $902,446 in federal funds for the School Breakfast Program, National School Lunch Program and Summer Food Service Program for Children. These programs provide funding for free and reduced-price meals for eligible students whose households meet specific income requirements set by the U.S. Department of Agriculture. Federal regulations require recipients to establish and maintain internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Federal requirements prohibit grant recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever a government enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify that the contractors have not been suspended, debarred or otherwise excluded. The District may accomplish this verification by obtaining a written certification from the contractor, inserting a clause or condition into the contract that states the contractor is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration?s System for Award Management at SAM.gov. The District must perform this verification before entering into the contract or before charging the costs to a federal award. Description of Condition The District?s controls were inadequate for ensuring that it verified all parties receiving $25,000 or more in federal funds were not suspended or debarred. The District did not obtain a written certification, include a clause in the contract, or search for exclusion records in SAM.gov to verify one of its two contractors subject to this requirement was not suspended or debarred. During fiscal year 2022, the District used $59,756 of program funds to pay this contractor for food services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District approved a contract for food services with a vendor who subsequently subcontracted the bid to another vendor. The District paid the subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. Effect of Condition Without adequate internal controls, the District cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any program funds the District used to pay a contractor that has been suspended or debarred would be unallowable, and the federal grantor could potentially recover them. We verified the contractor was not suspended or debarred, so we are not questioning costs. Recommendation We recommend the District strengthen its internal controls to ensure that all contractors paid $25,000 or more, all or in part with federal funds, are not suspended or debarred before entering into contracts with them or charging their costs to the federal programs. District?s Response It was stated that the District paid a subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. The District however does know that a verification needs to happen, but when the change happened in FY 2022, that was the same year of several staffing changes. The documents requested were difficult to locate as the Director of Finance at the time had retired and the Districts Food Service Director is currently out on a leave of absence. A suspension and debarment verification was provided for the audit, however it was not allowed as it did not reflect a print date. Moving forward, the District will ensure that all verifications have a date, with all documentation to be filed with the Director of Finance. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, 0MB Guidelines to Agencies on Government wide Debarment and Suspension (Nonprocurement) establishes non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. See Schedule of Findings and Questioned Costs for chart/table Background During fiscal year 2022, the District received $902,446 in federal funds for the School Breakfast Program, National School Lunch Program and Summer Food Service Program for Children. These programs provide funding for free and reduced-price meals for eligible students whose households meet specific income requirements set by the U.S. Department of Agriculture. Federal regulations require recipients to establish and maintain internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Federal requirements prohibit grant recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever a government enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify that the contractors have not been suspended, debarred or otherwise excluded. The District may accomplish this verification by obtaining a written certification from the contractor, inserting a clause or condition into the contract that states the contractor is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration?s System for Award Management at SAM.gov. The District must perform this verification before entering into the contract or before charging the costs to a federal award. Description of Condition The District?s controls were inadequate for ensuring that it verified all parties receiving $25,000 or more in federal funds were not suspended or debarred. The District did not obtain a written certification, include a clause in the contract, or search for exclusion records in SAM.gov to verify one of its two contractors subject to this requirement was not suspended or debarred. During fiscal year 2022, the District used $59,756 of program funds to pay this contractor for food services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District approved a contract for food services with a vendor who subsequently subcontracted the bid to another vendor. The District paid the subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. Effect of Condition Without adequate internal controls, the District cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any program funds the District used to pay a contractor that has been suspended or debarred would be unallowable, and the federal grantor could potentially recover them. We verified the contractor was not suspended or debarred, so we are not questioning costs. Recommendation We recommend the District strengthen its internal controls to ensure that all contractors paid $25,000 or more, all or in part with federal funds, are not suspended or debarred before entering into contracts with them or charging their costs to the federal programs. District?s Response It was stated that the District paid a subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. The District however does know that a verification needs to happen, but when the change happened in FY 2022, that was the same year of several staffing changes. The documents requested were difficult to locate as the Director of Finance at the time had retired and the Districts Food Service Director is currently out on a leave of absence. A suspension and debarment verification was provided for the audit, however it was not allowed as it did not reflect a print date. Moving forward, the District will ensure that all verifications have a date, with all documentation to be filed with the Director of Finance. Auditor?s Remarks We appreciate the District?s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, 0MB Guidelines to Agencies on Government wide Debarment and Suspension (Nonprocurement) establishes non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.