2025-002 Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: None Award Perio...
2025-002 Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: None Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: CLA recommends that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The recommendation was included in the FY2024 Single Audit Corrective Action Plan and the following course of action was described therein; The Purchasing Office had processes in place to ensure debarment status was checked before contract award. Both the contract checklist and the Qualifications Affidavit in the solicitation template contained debarment status language to ensure the necessary checks took place. Despite these processes, a contract for curriculum materials was not checked for debarment status before contract award. The cause of that oversight seems to be the different procurement processes used in instructional materials procurements. The contract was not competitively awarded, so they did not require a qualifications affidavit, which would have ensured the debarment status was checked. In this instance, a checklist was not included in the contract file as required, which would have also triggered a debarment check. In response, the Purchasing Office is adding a third layer of oversight - requiring that a revised contract affidavit is completed for every contract award. Language was added to the current contract affidavit that contains an affirmation by the contractor that they are not suspended or debarred by any government entity – local, state, and federal. To summarize, the Purchasing Office will engage one of the three processes listed below to ensure timely debarment checks are conducted on every contract, regardless of funding source. 1) Contract Checklist 2) Qualifications Affidavit 3) Contract Affidavit Contracts chosen in this FY25 sample all predate the implementation of the FY24 corrective action plan as they spanned multiple years. Debarment checks were performed for some of the contracts sampled, but the date of the printout was not legible for the audit team to review. The purchasing team will ensure that dates are legible. AACPS will continue with the process described above to ensure timely debarment checks are conducted. Name(s) of the contact person(s) responsible for corrective action: Mary Jo Childs, Director of Purchasing Planned completion date for corrective action plan: For immediate implementation and ongoing.