FAC Explorer

Audit 9575

FY End
2023-06-30
Total Expended
$10.22M
Findings
36
Programs
18
Organization: Redmond School District No. 2j (OR)
Year: 2023 Accepted: 2024-01-04
Auditor: Sensiba LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
7411 2023-001 - - I
7412 2023-002 Significant Deficiency - I
7413 2023-001 - - I
7414 2023-002 Significant Deficiency - I
7415 2023-001 - - I
7416 2023-002 Significant Deficiency - I
7417 2023-001 - - I
7418 2023-002 Significant Deficiency - I
7419 2023-001 - - I
7420 2023-002 Significant Deficiency - I
7421 2023-001 - - I
7422 2023-002 Significant Deficiency - I
7423 2023-001 - - I
7424 2023-002 Significant Deficiency - I
7425 2023-001 - - I
7426 2023-002 Significant Deficiency - I
7427 2023-001 - - I
7428 2023-002 Significant Deficiency - I
583853 2023-001 - - I
583854 2023-002 Significant Deficiency - I
583855 2023-001 - - I
583856 2023-002 Significant Deficiency - I
583857 2023-001 - - I
583858 2023-002 Significant Deficiency - I
583859 2023-001 - - I
583860 2023-002 Significant Deficiency - I
583861 2023-001 - - I
583862 2023-002 Significant Deficiency - I
583863 2023-001 - - I
583864 2023-002 Significant Deficiency - I
583865 2023-001 - - I
583866 2023-002 Significant Deficiency - I
583867 2023-001 - - I
583868 2023-002 Significant Deficiency - I
583869 2023-001 - - I
583870 2023-002 Significant Deficiency - I

Programs

ALN Program Spent Major Findings
84.010 Title I Grants to Local Educational Agencies $1.33M - 0
32.009 Emergency Connectivity Fund Program $485,332 - 0
10.553 School Breakfast Program $472,096 Yes 2
10.555 National School Lunch Program $269,084 Yes 2
84.367 Improving Teacher Quality State Grants $224,979 - 0
84.027 Special Education_grants to States $223,708 - 0
84.424 Student Support and Academic Enrichment Program $116,133 Yes 0
10.559 Summer Food Service Program for Children $82,494 Yes 2
10.665 Schools and Roads - Grants to States $80,011 - 0
10.558 Child and Adult Care Food Program $71,526 - 0
84.425 Education Stabilization Fund $48,158 Yes 0
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $44,360 - 0
84.365 English Language Acquisition State Grants $21,211 - 0
93.658 Foster Care_title IV-E $13,621 - 0
84.196 Education for Homeless Children and Youth $11,898 - 0
84.173 Special Education_preschool Grants $4,559 - 0
45.310 Grants to States $2,655 - 0
10.582 Fresh Fruit and Vegetable Program $109 Yes 2

Contacts

Name Title Type
GGCQMJRUFLJ2 Kathy Steinert Auditee
5419238927 Brenda Bartlett Auditor
No contacts on file

Notes to SEFA

Title: Note A- Purpose of Schedule Accounting Policies: Basis of Presentation - Expenditures on the SEFA are reported on the modified accrual basis of accounting. Revenues are recorded when measurable and available, or in the case of grants where the expenditure is the prime factor for determining eligibility, when the expenditure is made. Expenditures are recorded when a liability is incurred. Such expenditures are recognized using the Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. The District has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance, but rather use a rate approved by the Oregon Department of Education each year. For fiscal year ended June 30, 2023, the rate was 3.40 percent. Federal Financial Assistance – Pursuant to the Uniform Guidance, federal financial assistance is defined as assistance provided by a federal agency, either directly or indirectly, in the form of grants, contracts, cooperative agreements, loans, loan guarantees, property, interest subsidies, insurance or direct appropriations. Accordingly, nonmonetary federal assistance, including federal surplus property, is included in federal financial assistance and, therefore, is reported on the Schedule, if applicable. Federal financial assistance does not include direct federal cash assistance to individuals. Solicited contracts between the state and federal government for which the federal government procures tangible goods or services are not considered to be federal financial assistance. Major Programs – The Uniform Guidance establishes criteria to be used in defining major federal financial assistance programs. Major programs for the District are those programs selected for testing by the auditor using a risk-assessment model, as well as certain minimum expenditure requirements, as outlined in the Uniform Guidance. Programs with similar requirements may be grouped into a cluster for testing purposes. De Minimis Rate Used: N Rate Explanation: The District has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance, but rather use a rate approved by the Oregon Department of Education each year. For fiscal year ended June 30, 2023, the rate was 3.40 percent. The accompanying Schedule of Expenditures of Federal Awards (SEFA) includes the federal award activity of Redmond School District No. 2J (the District). The information in this schedule is prepared in accordance with the requirements of Title 2 US Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the SEFA presents only a selected portion of the operations of the District, it is not intended to and does not present the financial position or changes in net position of the District.
Title: Note B- Summary of Significant accounting policies Accounting Policies: Basis of Presentation - Expenditures on the SEFA are reported on the modified accrual basis of accounting. Revenues are recorded when measurable and available, or in the case of grants where the expenditure is the prime factor for determining eligibility, when the expenditure is made. Expenditures are recorded when a liability is incurred. Such expenditures are recognized using the Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. The District has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance, but rather use a rate approved by the Oregon Department of Education each year. For fiscal year ended June 30, 2023, the rate was 3.40 percent. Federal Financial Assistance – Pursuant to the Uniform Guidance, federal financial assistance is defined as assistance provided by a federal agency, either directly or indirectly, in the form of grants, contracts, cooperative agreements, loans, loan guarantees, property, interest subsidies, insurance or direct appropriations. Accordingly, nonmonetary federal assistance, including federal surplus property, is included in federal financial assistance and, therefore, is reported on the Schedule, if applicable. Federal financial assistance does not include direct federal cash assistance to individuals. Solicited contracts between the state and federal government for which the federal government procures tangible goods or services are not considered to be federal financial assistance. Major Programs – The Uniform Guidance establishes criteria to be used in defining major federal financial assistance programs. Major programs for the District are those programs selected for testing by the auditor using a risk-assessment model, as well as certain minimum expenditure requirements, as outlined in the Uniform Guidance. Programs with similar requirements may be grouped into a cluster for testing purposes. De Minimis Rate Used: N Rate Explanation: The District has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance, but rather use a rate approved by the Oregon Department of Education each year. For fiscal year ended June 30, 2023, the rate was 3.40 percent. Basis of Presentation - Expenditures on the SEFA are reported on the modified accrual basis of accounting. Revenues are recorded when measurable and available, or in the case of grants where the expenditure is the prime factor for determining eligibility, when the expenditure is made. Expenditures are recorded when a liability is incurred. Such expenditures are recognized using the Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. The District has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance, but rather use a rate approved by the Oregon Department of Education each year. For fiscal year ended June 30, 2023, the rate was 3.40 percent. Federal Financial Assistance – Pursuant to the Uniform Guidance, federal financial assistance is defined as assistance provided by a federal agency, either directly or indirectly, in the form of grants, contracts, cooperative agreements, loans, loan guarantees, property, interest subsidies, insurance or direct appropriations. Accordingly, nonmonetary federal assistance, including federal surplus property, is included in federal financial assistance and, therefore, is reported on the Schedule, if applicable. Federal financial assistance does not include direct federal cash assistance to individuals. Solicited contracts between the state and federal government for which the federal government procures tangible goods or services are not considered to be federal financial assistance. Major Programs – The Uniform Guidance establishes criteria to be used in defining major federal financial assistance programs. Major programs for the District are those programs selected for testing by the auditor using a risk-assessment model, as well as certain minimum expenditure requirements, as outlined in the Uniform Guidance. Programs with similar requirements may be grouped into a cluster for testing purposes.
Title: Note C- Child nutrition cluster Accounting Policies: Basis of Presentation - Expenditures on the SEFA are reported on the modified accrual basis of accounting. Revenues are recorded when measurable and available, or in the case of grants where the expenditure is the prime factor for determining eligibility, when the expenditure is made. Expenditures are recorded when a liability is incurred. Such expenditures are recognized using the Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. The District has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance, but rather use a rate approved by the Oregon Department of Education each year. For fiscal year ended June 30, 2023, the rate was 3.40 percent. Federal Financial Assistance – Pursuant to the Uniform Guidance, federal financial assistance is defined as assistance provided by a federal agency, either directly or indirectly, in the form of grants, contracts, cooperative agreements, loans, loan guarantees, property, interest subsidies, insurance or direct appropriations. Accordingly, nonmonetary federal assistance, including federal surplus property, is included in federal financial assistance and, therefore, is reported on the Schedule, if applicable. Federal financial assistance does not include direct federal cash assistance to individuals. Solicited contracts between the state and federal government for which the federal government procures tangible goods or services are not considered to be federal financial assistance. Major Programs – The Uniform Guidance establishes criteria to be used in defining major federal financial assistance programs. Major programs for the District are those programs selected for testing by the auditor using a risk-assessment model, as well as certain minimum expenditure requirements, as outlined in the Uniform Guidance. Programs with similar requirements may be grouped into a cluster for testing purposes. De Minimis Rate Used: N Rate Explanation: The District has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance, but rather use a rate approved by the Oregon Department of Education each year. For fiscal year ended June 30, 2023, the rate was 3.40 percent. The District commingles cash receipts from the US Department of Agriculture with similar state grants. When reporting expenditures on this schedule, the District assumes it expends federal monies first. The District reports commodities consumed on the schedule at fair value.

Finding Details

Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-001
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. One of the procurements was of a nature that an emergency procurement would have been allowed, however the District did not document justification for a noncompetitive procurement as required. Cause: Management in charge of the Child Nutrition program did not document the emergency procurement or consider that individual service procurements might exceed the micro purchase threshold once aggregated for the fiscal year. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.
Finding 2023-002
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive methods. Condition: Two vendors provided goods or services in excess of the micro purchase threshold without having been procured through a competitive process. Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure compliance with federal procurement requirements. Effect: Competitive procurement methods were not used for two procurements and noncompetitive procurement justifications were not documented. Context: The error was isolated to two procurements exceeding the micro purchase threshold. Recommendation: We recommend the District implement formal written policies for ensuring that procurement is monitored at least annually to identify potential goods or services that may exceed the micro purchase threshold during the fiscal year and require a competitive procurement method. Emergency procurements should be documented, in writing, in order to justify the use of noncompetitive methods. Views of responsible officials: The District’s Nutrition Services Program has previously documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022 as part of a Procurement Compliance Review performed by the Oregon Department of Education. The procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or services. Additionally, the procedures state “the Director of Nutrition Services or their designee is responsible for the documentation of records to fully explain the decision to use the noncompetitive negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or services to the Director of Nutrition Services or their designee in order to determine if any procurements are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their designee will conduct the appropriate competitive procurement(s) in accordance with District procedures, if necessary.