FA 2022-001 Strengthen Controls over Special Reporting
Compliance Requirement: Reporting
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: None Identified
Description:
The policies and procedures of the School District were insufficient to provide adequate internal
controls over the monthly Claims for Reimbursement process.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential child care institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) based
upon each School District’s monthly Form DE0106 Claim Data report submissions. These DE0106
reports are to be supported by the corresponding Form DE0112 Daily Record of Number of Breakfasts
Served and Form DE0118 Daily Record of Number of Lunches Served, which are prepared by the School
District from their School Food Service meal sales system.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Provisions included in Title 7 CFR Section 210.7(c) require that the School District "base Claims for
Reimbursement on lunch counts, taken daily at the point of service, which correctly identify the number
of free, reduced price and paid lunches served to eligible children" and "correctly record, consolidate
and report those lunch and supplement counts on the Claim for Reimbursement."
In addition, provisions included in Title 7 CFR Section 220.11(d) state that the School District "shall
establish internal controls which ensure the accuracy of breakfast counts prior to the submission of the
monthly Claim for Reimbursement.”
Condition:
A sample of three Form DE0106 reports was randomly selected for testing using a non-statistical
sampling approach. Additionally, the Form DE0106 reports for the months of July 2021 and June 2022
were selected for testing. These reports were reviewed to determine if appropriate internal controls
were implemented and applicable reporting compliance requirements were met. The following
deficiencies were noted:
No Form DE0112 or DE0118 reports were prepared during the period under review.
Daily meal count sheets maintained by the schools did not reflect evidence of review and
approval by lunchroom managers in six instances.
Meal count errors were noted for three out of five months tested. The number of meals served
per the daily meal count sheets for these three months did not match the number of meals
reported and claimed on the Form DE0106 reports resulting in the under-claiming of 732 lunch
or breakfast meals during the period under review.
Cause:
In discussing these deficiencies with management, the School District believed completion of DE0112 and
DE0018 was not a requirement due to the election of the Seamless Summer Option. As a result, the
School District did not follow its policies and procedures that govern the reporting process for federal
programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to
submit accurate monthly Claims for Reimbursement to GaDOE can result in the School District
obtaining less federal funding than they are eligible to receive. This deficiency may expose the School
District to unnecessary financial strains and shortages within the CNC fund.
Recommendation:
The School District should evaluate their internal control processes regarding the creation of the Form
DE0106 reports and develop or modify procedures to ensure Claims for Reimbursement are based on
final and accurate meals counts. The School District should become more familiar with the Federal
regulations related to the CNC programs in order to develop or modify procedures that will ensure
accurate reporting of meals served. Furthermore, management should develop and implement a
monitoring process to ensure that controls are functioning properly.
Views of Responsible Officials:
We concur with this finding.
FA 2022-001 Strengthen Controls over Special Reporting
Compliance Requirement: Reporting
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: None Identified
Description:
The policies and procedures of the School District were insufficient to provide adequate internal
controls over the monthly Claims for Reimbursement process.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential child care institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) based
upon each School District’s monthly Form DE0106 Claim Data report submissions. These DE0106
reports are to be supported by the corresponding Form DE0112 Daily Record of Number of Breakfasts
Served and Form DE0118 Daily Record of Number of Lunches Served, which are prepared by the School
District from their School Food Service meal sales system.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Provisions included in Title 7 CFR Section 210.7(c) require that the School District "base Claims for
Reimbursement on lunch counts, taken daily at the point of service, which correctly identify the number
of free, reduced price and paid lunches served to eligible children" and "correctly record, consolidate
and report those lunch and supplement counts on the Claim for Reimbursement."
In addition, provisions included in Title 7 CFR Section 220.11(d) state that the School District "shall
establish internal controls which ensure the accuracy of breakfast counts prior to the submission of the
monthly Claim for Reimbursement.”
Condition:
A sample of three Form DE0106 reports was randomly selected for testing using a non-statistical
sampling approach. Additionally, the Form DE0106 reports for the months of July 2021 and June 2022
were selected for testing. These reports were reviewed to determine if appropriate internal controls
were implemented and applicable reporting compliance requirements were met. The following
deficiencies were noted:
No Form DE0112 or DE0118 reports were prepared during the period under review.
Daily meal count sheets maintained by the schools did not reflect evidence of review and
approval by lunchroom managers in six instances.
Meal count errors were noted for three out of five months tested. The number of meals served
per the daily meal count sheets for these three months did not match the number of meals
reported and claimed on the Form DE0106 reports resulting in the under-claiming of 732 lunch
or breakfast meals during the period under review.
Cause:
In discussing these deficiencies with management, the School District believed completion of DE0112 and
DE0018 was not a requirement due to the election of the Seamless Summer Option. As a result, the
School District did not follow its policies and procedures that govern the reporting process for federal
programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to
submit accurate monthly Claims for Reimbursement to GaDOE can result in the School District
obtaining less federal funding than they are eligible to receive. This deficiency may expose the School
District to unnecessary financial strains and shortages within the CNC fund.
Recommendation:
The School District should evaluate their internal control processes regarding the creation of the Form
DE0106 reports and develop or modify procedures to ensure Claims for Reimbursement are based on
final and accurate meals counts. The School District should become more familiar with the Federal
regulations related to the CNC programs in order to develop or modify procedures that will ensure
accurate reporting of meals served. Furthermore, management should develop and implement a
monitoring process to ensure that controls are functioning properly.
Views of Responsible Officials:
We concur with this finding.
FA 2022-001 Strengthen Controls over Special Reporting
Compliance Requirement: Reporting
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: None Identified
Description:
The policies and procedures of the School District were insufficient to provide adequate internal
controls over the monthly Claims for Reimbursement process.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential child care institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) based
upon each School District’s monthly Form DE0106 Claim Data report submissions. These DE0106
reports are to be supported by the corresponding Form DE0112 Daily Record of Number of Breakfasts
Served and Form DE0118 Daily Record of Number of Lunches Served, which are prepared by the School
District from their School Food Service meal sales system.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Provisions included in Title 7 CFR Section 210.7(c) require that the School District "base Claims for
Reimbursement on lunch counts, taken daily at the point of service, which correctly identify the number
of free, reduced price and paid lunches served to eligible children" and "correctly record, consolidate
and report those lunch and supplement counts on the Claim for Reimbursement."
In addition, provisions included in Title 7 CFR Section 220.11(d) state that the School District "shall
establish internal controls which ensure the accuracy of breakfast counts prior to the submission of the
monthly Claim for Reimbursement.”
Condition:
A sample of three Form DE0106 reports was randomly selected for testing using a non-statistical
sampling approach. Additionally, the Form DE0106 reports for the months of July 2021 and June 2022
were selected for testing. These reports were reviewed to determine if appropriate internal controls
were implemented and applicable reporting compliance requirements were met. The following
deficiencies were noted:
No Form DE0112 or DE0118 reports were prepared during the period under review.
Daily meal count sheets maintained by the schools did not reflect evidence of review and
approval by lunchroom managers in six instances.
Meal count errors were noted for three out of five months tested. The number of meals served
per the daily meal count sheets for these three months did not match the number of meals
reported and claimed on the Form DE0106 reports resulting in the under-claiming of 732 lunch
or breakfast meals during the period under review.
Cause:
In discussing these deficiencies with management, the School District believed completion of DE0112 and
DE0018 was not a requirement due to the election of the Seamless Summer Option. As a result, the
School District did not follow its policies and procedures that govern the reporting process for federal
programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to
submit accurate monthly Claims for Reimbursement to GaDOE can result in the School District
obtaining less federal funding than they are eligible to receive. This deficiency may expose the School
District to unnecessary financial strains and shortages within the CNC fund.
Recommendation:
The School District should evaluate their internal control processes regarding the creation of the Form
DE0106 reports and develop or modify procedures to ensure Claims for Reimbursement are based on
final and accurate meals counts. The School District should become more familiar with the Federal
regulations related to the CNC programs in order to develop or modify procedures that will ensure
accurate reporting of meals served. Furthermore, management should develop and implement a
monitoring process to ensure that controls are functioning properly.
Views of Responsible Officials:
We concur with this finding.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: $474.00
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s
internal control procedures were not operating appropriately to ensure that the School District’s
procurement procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential childcare institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and
overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported
on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for
fiscal year 2022.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement
Standards state in part that “(a) the non-Federal entity must use its own documented procurement
procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal
entities must maintain oversight to ensure that contractors perform in accordance with the terms,
conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in
the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance
for procurement through small purchase procedures and state “If small purchase procedures are used,
price or rate quotations must be obtained from an adequate number of qualified sources.”
Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that
the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a)
Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the
entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of 40 procurement transactions was randomly selected for testing using a non-statistical
sampling approach. These expenditures were reviewed to determine if appropriate internal controls
were implemented, and applicable procurement compliance requirements were met. The following
deficiencies were noted:
The appropriate procurement method was not used for the dollar amount and conditions
associated with one procurement transaction.
The School District could not provide evidence that an adequate number of rate or price
quotations was obtained from qualified sources for one small purchase expenditure reviewed.
In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical
sampling approach. These transactions were reviewed to determine if appropriate internal
controls were implemented and if suspension and debarment compliance requirements were met. The
following exception was noted:
For two expenditures, documentation could not be provided to support the entity’s verification
that the vendor was not suspended or debarred or otherwise excluded from participating in the
transaction.
Questioned Costs:
Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00
were identified for expenditures that did not follow the School District’s procurement procedures.
Using the total population of $1,363,942.86 in procurement transactions, we project the likely
questioned costs to be approximately $48,623.00.
Cause:
The School District did not follow its policies and procedures that govern the procurement process for
federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and Georgia Department of
Education guidance. Failure to appropriately implement procedures to address procurement
compliance requirements could result in the expenditure of federal funds with unqualified vendors and
the return of grant funds associated with these unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required
procurement methods are properly identified and followed. Furthermore, management should develop
a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: $474.00
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s
internal control procedures were not operating appropriately to ensure that the School District’s
procurement procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential childcare institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and
overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported
on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for
fiscal year 2022.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement
Standards state in part that “(a) the non-Federal entity must use its own documented procurement
procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal
entities must maintain oversight to ensure that contractors perform in accordance with the terms,
conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in
the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance
for procurement through small purchase procedures and state “If small purchase procedures are used,
price or rate quotations must be obtained from an adequate number of qualified sources.”
Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that
the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a)
Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the
entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of 40 procurement transactions was randomly selected for testing using a non-statistical
sampling approach. These expenditures were reviewed to determine if appropriate internal controls
were implemented, and applicable procurement compliance requirements were met. The following
deficiencies were noted:
The appropriate procurement method was not used for the dollar amount and conditions
associated with one procurement transaction.
The School District could not provide evidence that an adequate number of rate or price
quotations was obtained from qualified sources for one small purchase expenditure reviewed.
In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical
sampling approach. These transactions were reviewed to determine if appropriate internal
controls were implemented and if suspension and debarment compliance requirements were met. The
following exception was noted:
For two expenditures, documentation could not be provided to support the entity’s verification
that the vendor was not suspended or debarred or otherwise excluded from participating in the
transaction.
Questioned Costs:
Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00
were identified for expenditures that did not follow the School District’s procurement procedures.
Using the total population of $1,363,942.86 in procurement transactions, we project the likely
questioned costs to be approximately $48,623.00.
Cause:
The School District did not follow its policies and procedures that govern the procurement process for
federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and Georgia Department of
Education guidance. Failure to appropriately implement procedures to address procurement
compliance requirements could result in the expenditure of federal funds with unqualified vendors and
the return of grant funds associated with these unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required
procurement methods are properly identified and followed. Furthermore, management should develop
a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: $474.00
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s
internal control procedures were not operating appropriately to ensure that the School District’s
procurement procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential childcare institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and
overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported
on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for
fiscal year 2022.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement
Standards state in part that “(a) the non-Federal entity must use its own documented procurement
procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal
entities must maintain oversight to ensure that contractors perform in accordance with the terms,
conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in
the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance
for procurement through small purchase procedures and state “If small purchase procedures are used,
price or rate quotations must be obtained from an adequate number of qualified sources.”
Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that
the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a)
Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the
entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of 40 procurement transactions was randomly selected for testing using a non-statistical
sampling approach. These expenditures were reviewed to determine if appropriate internal controls
were implemented, and applicable procurement compliance requirements were met. The following
deficiencies were noted:
The appropriate procurement method was not used for the dollar amount and conditions
associated with one procurement transaction.
The School District could not provide evidence that an adequate number of rate or price
quotations was obtained from qualified sources for one small purchase expenditure reviewed.
In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical
sampling approach. These transactions were reviewed to determine if appropriate internal
controls were implemented and if suspension and debarment compliance requirements were met. The
following exception was noted:
For two expenditures, documentation could not be provided to support the entity’s verification
that the vendor was not suspended or debarred or otherwise excluded from participating in the
transaction.
Questioned Costs:
Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00
were identified for expenditures that did not follow the School District’s procurement procedures.
Using the total population of $1,363,942.86 in procurement transactions, we project the likely
questioned costs to be approximately $48,623.00.
Cause:
The School District did not follow its policies and procedures that govern the procurement process for
federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and Georgia Department of
Education guidance. Failure to appropriately implement procedures to address procurement
compliance requirements could result in the expenditure of federal funds with unqualified vendors and
the return of grant funds associated with these unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required
procurement methods are properly identified and followed. Furthermore, management should develop
a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding.
FA 2022-001 Strengthen Controls over Special Reporting
Compliance Requirement: Reporting
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: None Identified
Description:
The policies and procedures of the School District were insufficient to provide adequate internal
controls over the monthly Claims for Reimbursement process.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential child care institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) based
upon each School District’s monthly Form DE0106 Claim Data report submissions. These DE0106
reports are to be supported by the corresponding Form DE0112 Daily Record of Number of Breakfasts
Served and Form DE0118 Daily Record of Number of Lunches Served, which are prepared by the School
District from their School Food Service meal sales system.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Provisions included in Title 7 CFR Section 210.7(c) require that the School District "base Claims for
Reimbursement on lunch counts, taken daily at the point of service, which correctly identify the number
of free, reduced price and paid lunches served to eligible children" and "correctly record, consolidate
and report those lunch and supplement counts on the Claim for Reimbursement."
In addition, provisions included in Title 7 CFR Section 220.11(d) state that the School District "shall
establish internal controls which ensure the accuracy of breakfast counts prior to the submission of the
monthly Claim for Reimbursement.”
Condition:
A sample of three Form DE0106 reports was randomly selected for testing using a non-statistical
sampling approach. Additionally, the Form DE0106 reports for the months of July 2021 and June 2022
were selected for testing. These reports were reviewed to determine if appropriate internal controls
were implemented and applicable reporting compliance requirements were met. The following
deficiencies were noted:
No Form DE0112 or DE0118 reports were prepared during the period under review.
Daily meal count sheets maintained by the schools did not reflect evidence of review and
approval by lunchroom managers in six instances.
Meal count errors were noted for three out of five months tested. The number of meals served
per the daily meal count sheets for these three months did not match the number of meals
reported and claimed on the Form DE0106 reports resulting in the under-claiming of 732 lunch
or breakfast meals during the period under review.
Cause:
In discussing these deficiencies with management, the School District believed completion of DE0112 and
DE0018 was not a requirement due to the election of the Seamless Summer Option. As a result, the
School District did not follow its policies and procedures that govern the reporting process for federal
programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to
submit accurate monthly Claims for Reimbursement to GaDOE can result in the School District
obtaining less federal funding than they are eligible to receive. This deficiency may expose the School
District to unnecessary financial strains and shortages within the CNC fund.
Recommendation:
The School District should evaluate their internal control processes regarding the creation of the Form
DE0106 reports and develop or modify procedures to ensure Claims for Reimbursement are based on
final and accurate meals counts. The School District should become more familiar with the Federal
regulations related to the CNC programs in order to develop or modify procedures that will ensure
accurate reporting of meals served. Furthermore, management should develop and implement a
monitoring process to ensure that controls are functioning properly.
Views of Responsible Officials:
We concur with this finding.
FA 2022-001 Strengthen Controls over Special Reporting
Compliance Requirement: Reporting
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: None Identified
Description:
The policies and procedures of the School District were insufficient to provide adequate internal
controls over the monthly Claims for Reimbursement process.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential child care institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) based
upon each School District’s monthly Form DE0106 Claim Data report submissions. These DE0106
reports are to be supported by the corresponding Form DE0112 Daily Record of Number of Breakfasts
Served and Form DE0118 Daily Record of Number of Lunches Served, which are prepared by the School
District from their School Food Service meal sales system.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Provisions included in Title 7 CFR Section 210.7(c) require that the School District "base Claims for
Reimbursement on lunch counts, taken daily at the point of service, which correctly identify the number
of free, reduced price and paid lunches served to eligible children" and "correctly record, consolidate
and report those lunch and supplement counts on the Claim for Reimbursement."
In addition, provisions included in Title 7 CFR Section 220.11(d) state that the School District "shall
establish internal controls which ensure the accuracy of breakfast counts prior to the submission of the
monthly Claim for Reimbursement.”
Condition:
A sample of three Form DE0106 reports was randomly selected for testing using a non-statistical
sampling approach. Additionally, the Form DE0106 reports for the months of July 2021 and June 2022
were selected for testing. These reports were reviewed to determine if appropriate internal controls
were implemented and applicable reporting compliance requirements were met. The following
deficiencies were noted:
No Form DE0112 or DE0118 reports were prepared during the period under review.
Daily meal count sheets maintained by the schools did not reflect evidence of review and
approval by lunchroom managers in six instances.
Meal count errors were noted for three out of five months tested. The number of meals served
per the daily meal count sheets for these three months did not match the number of meals
reported and claimed on the Form DE0106 reports resulting in the under-claiming of 732 lunch
or breakfast meals during the period under review.
Cause:
In discussing these deficiencies with management, the School District believed completion of DE0112 and
DE0018 was not a requirement due to the election of the Seamless Summer Option. As a result, the
School District did not follow its policies and procedures that govern the reporting process for federal
programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to
submit accurate monthly Claims for Reimbursement to GaDOE can result in the School District
obtaining less federal funding than they are eligible to receive. This deficiency may expose the School
District to unnecessary financial strains and shortages within the CNC fund.
Recommendation:
The School District should evaluate their internal control processes regarding the creation of the Form
DE0106 reports and develop or modify procedures to ensure Claims for Reimbursement are based on
final and accurate meals counts. The School District should become more familiar with the Federal
regulations related to the CNC programs in order to develop or modify procedures that will ensure
accurate reporting of meals served. Furthermore, management should develop and implement a
monitoring process to ensure that controls are functioning properly.
Views of Responsible Officials:
We concur with this finding.
FA 2022-001 Strengthen Controls over Special Reporting
Compliance Requirement: Reporting
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: None Identified
Description:
The policies and procedures of the School District were insufficient to provide adequate internal
controls over the monthly Claims for Reimbursement process.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential child care institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) based
upon each School District’s monthly Form DE0106 Claim Data report submissions. These DE0106
reports are to be supported by the corresponding Form DE0112 Daily Record of Number of Breakfasts
Served and Form DE0118 Daily Record of Number of Lunches Served, which are prepared by the School
District from their School Food Service meal sales system.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Provisions included in Title 7 CFR Section 210.7(c) require that the School District "base Claims for
Reimbursement on lunch counts, taken daily at the point of service, which correctly identify the number
of free, reduced price and paid lunches served to eligible children" and "correctly record, consolidate
and report those lunch and supplement counts on the Claim for Reimbursement."
In addition, provisions included in Title 7 CFR Section 220.11(d) state that the School District "shall
establish internal controls which ensure the accuracy of breakfast counts prior to the submission of the
monthly Claim for Reimbursement.”
Condition:
A sample of three Form DE0106 reports was randomly selected for testing using a non-statistical
sampling approach. Additionally, the Form DE0106 reports for the months of July 2021 and June 2022
were selected for testing. These reports were reviewed to determine if appropriate internal controls
were implemented and applicable reporting compliance requirements were met. The following
deficiencies were noted:
No Form DE0112 or DE0118 reports were prepared during the period under review.
Daily meal count sheets maintained by the schools did not reflect evidence of review and
approval by lunchroom managers in six instances.
Meal count errors were noted for three out of five months tested. The number of meals served
per the daily meal count sheets for these three months did not match the number of meals
reported and claimed on the Form DE0106 reports resulting in the under-claiming of 732 lunch
or breakfast meals during the period under review.
Cause:
In discussing these deficiencies with management, the School District believed completion of DE0112 and
DE0018 was not a requirement due to the election of the Seamless Summer Option. As a result, the
School District did not follow its policies and procedures that govern the reporting process for federal
programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to
submit accurate monthly Claims for Reimbursement to GaDOE can result in the School District
obtaining less federal funding than they are eligible to receive. This deficiency may expose the School
District to unnecessary financial strains and shortages within the CNC fund.
Recommendation:
The School District should evaluate their internal control processes regarding the creation of the Form
DE0106 reports and develop or modify procedures to ensure Claims for Reimbursement are based on
final and accurate meals counts. The School District should become more familiar with the Federal
regulations related to the CNC programs in order to develop or modify procedures that will ensure
accurate reporting of meals served. Furthermore, management should develop and implement a
monitoring process to ensure that controls are functioning properly.
Views of Responsible Officials:
We concur with this finding.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: $474.00
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s
internal control procedures were not operating appropriately to ensure that the School District’s
procurement procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential childcare institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and
overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported
on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for
fiscal year 2022.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement
Standards state in part that “(a) the non-Federal entity must use its own documented procurement
procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal
entities must maintain oversight to ensure that contractors perform in accordance with the terms,
conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in
the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance
for procurement through small purchase procedures and state “If small purchase procedures are used,
price or rate quotations must be obtained from an adequate number of qualified sources.”
Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that
the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a)
Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the
entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of 40 procurement transactions was randomly selected for testing using a non-statistical
sampling approach. These expenditures were reviewed to determine if appropriate internal controls
were implemented, and applicable procurement compliance requirements were met. The following
deficiencies were noted:
The appropriate procurement method was not used for the dollar amount and conditions
associated with one procurement transaction.
The School District could not provide evidence that an adequate number of rate or price
quotations was obtained from qualified sources for one small purchase expenditure reviewed.
In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical
sampling approach. These transactions were reviewed to determine if appropriate internal
controls were implemented and if suspension and debarment compliance requirements were met. The
following exception was noted:
For two expenditures, documentation could not be provided to support the entity’s verification
that the vendor was not suspended or debarred or otherwise excluded from participating in the
transaction.
Questioned Costs:
Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00
were identified for expenditures that did not follow the School District’s procurement procedures.
Using the total population of $1,363,942.86 in procurement transactions, we project the likely
questioned costs to be approximately $48,623.00.
Cause:
The School District did not follow its policies and procedures that govern the procurement process for
federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and Georgia Department of
Education guidance. Failure to appropriately implement procedures to address procurement
compliance requirements could result in the expenditure of federal funds with unqualified vendors and
the return of grant funds associated with these unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required
procurement methods are properly identified and followed. Furthermore, management should develop
a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: $474.00
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s
internal control procedures were not operating appropriately to ensure that the School District’s
procurement procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential childcare institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and
overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported
on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for
fiscal year 2022.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement
Standards state in part that “(a) the non-Federal entity must use its own documented procurement
procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal
entities must maintain oversight to ensure that contractors perform in accordance with the terms,
conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in
the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance
for procurement through small purchase procedures and state “If small purchase procedures are used,
price or rate quotations must be obtained from an adequate number of qualified sources.”
Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that
the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a)
Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the
entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of 40 procurement transactions was randomly selected for testing using a non-statistical
sampling approach. These expenditures were reviewed to determine if appropriate internal controls
were implemented, and applicable procurement compliance requirements were met. The following
deficiencies were noted:
The appropriate procurement method was not used for the dollar amount and conditions
associated with one procurement transaction.
The School District could not provide evidence that an adequate number of rate or price
quotations was obtained from qualified sources for one small purchase expenditure reviewed.
In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical
sampling approach. These transactions were reviewed to determine if appropriate internal
controls were implemented and if suspension and debarment compliance requirements were met. The
following exception was noted:
For two expenditures, documentation could not be provided to support the entity’s verification
that the vendor was not suspended or debarred or otherwise excluded from participating in the
transaction.
Questioned Costs:
Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00
were identified for expenditures that did not follow the School District’s procurement procedures.
Using the total population of $1,363,942.86 in procurement transactions, we project the likely
questioned costs to be approximately $48,623.00.
Cause:
The School District did not follow its policies and procedures that govern the procurement process for
federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and Georgia Department of
Education guidance. Failure to appropriately implement procedures to address procurement
compliance requirements could result in the expenditure of federal funds with unqualified vendors and
the return of grant funds associated with these unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required
procurement methods are properly identified and followed. Furthermore, management should develop
a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: $474.00
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s
internal control procedures were not operating appropriately to ensure that the School District’s
procurement procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential childcare institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and
overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported
on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for
fiscal year 2022.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective
internal control over federal awards that provides reasonable assurance of managing the federal awards
in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to 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 200.303 – Internal Controls.
Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement
Standards state in part that “(a) the non-Federal entity must use its own documented procurement
procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal
entities must maintain oversight to ensure that contractors perform in accordance with the terms,
conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in
the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance
for procurement through small purchase procedures and state “If small purchase procedures are used,
price or rate quotations must be obtained from an adequate number of qualified sources.”
Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that
the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a)
Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the
entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of 40 procurement transactions was randomly selected for testing using a non-statistical
sampling approach. These expenditures were reviewed to determine if appropriate internal controls
were implemented, and applicable procurement compliance requirements were met. The following
deficiencies were noted:
The appropriate procurement method was not used for the dollar amount and conditions
associated with one procurement transaction.
The School District could not provide evidence that an adequate number of rate or price
quotations was obtained from qualified sources for one small purchase expenditure reviewed.
In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical
sampling approach. These transactions were reviewed to determine if appropriate internal
controls were implemented and if suspension and debarment compliance requirements were met. The
following exception was noted:
For two expenditures, documentation could not be provided to support the entity’s verification
that the vendor was not suspended or debarred or otherwise excluded from participating in the
transaction.
Questioned Costs:
Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00
were identified for expenditures that did not follow the School District’s procurement procedures.
Using the total population of $1,363,942.86 in procurement transactions, we project the likely
questioned costs to be approximately $48,623.00.
Cause:
The School District did not follow its policies and procedures that govern the procurement process for
federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and Georgia Department of
Education guidance. Failure to appropriately implement procedures to address procurement
compliance requirements could result in the expenditure of federal funds with unqualified vendors and
the return of grant funds associated with these unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required
procurement methods are properly identified and followed. Furthermore, management should develop
a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding.