Finding 2023-001: Procurement
United States Department of Agriculture – Child Nutrition Cluster
United States Department of Agriculture – Child and Adult Care Food Program
Criteria: The non-federal entity must maintain records sufficient to detail the history of
procurement. These records will inclu...
Finding 2023-001: Procurement
United States Department of Agriculture – Child Nutrition Cluster
United States Department of Agriculture – Child and Adult Care Food Program
Criteria: The non-federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to, the following:
Rational for the method of procurement, selection of contract type, contractor selection or
rejection, and the basis for the contract price (2 CFR section 200.318(i)). The non-federal entity
must also establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-federal entity is managing the Federal award in compliance
with Federal statutes, regulations, and the terms and conditions of the Federal award. These
internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the
“Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO) (2 CFR section 200.303(a)).
Condition: Records detailing which vendors were contacted, when they were contacted, and
support for the rationale in choosing the vendor, is not documented.
Questioned Costs: None
Cause: Management did not maintain a detailed history of procurement and did not document
a review process.
Effect: There is no reasonable assurance that the Organization managed the federal awards in
compliance with federal statutes, regulations, and the terms and conditions of the federal award
Recommendation: Purchasers should record, and keep on file, backup detailing which
vendors were contacted, when they were contacted, support for the rationale in choosing the
vendor. Management should implement a system of internal controls for this process.
Planned Corrective Action: Shloma Weiss, Administrative Director, will establish and
implement a process for documenting the procurement history and establishing a system of
internal controls.