Child Nutrition Cluster - Procurement. Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing Numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: 2 CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. They are however, checking the status of any new vendors. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.314 and 2 CFR Part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Perspective Information: As part of the requirements under the Uniform Guidance, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Questioned Cost: None. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The Business Manager will review these requirements with the Sr. Account Clerk. The Sr. Account Clerk will verify that all vendors are eligible to participate in the federal assistance program on an annual basis. Specifically, a note will be entered on the vendor record in the accounting system each time a purchase order is issued, which will detail that the proper verification was performed.
Child Nutrition Cluster - Procurement. Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of various vendors, we noted that the District is not following its procurement procedures for the Child Nutrition program purchases and is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.314 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214. The District is not performing required procedures; as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the school lunch fund and therefore represented purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR part 180 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure procurement procedures are being followed. Further, the District will perform and document a review of the eligibility of vendors to participate in Federal assistance programs. The District is in the process of corrective action, and is working toward compliance.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children Assistance Listing numbers 10.553, 10.555, and 10.556) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. They are however, checking the status of any new vendors. In addition, the District does not have any procedures in place to verify purchases against the bidding documents for pricing. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.314 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. The District could also be overpaying for goods as the bid documentation is not being verified against the purchases made. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Also as part of the required follow up of prior year audit findings, inquiries were performed to determine if bidding and procurement procedures were being followed, and they were not. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. The District should also implement procedures to verify their purchases against bidding documentation to ensure that they are paying the correct, bid upon price for their purchases. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.
Finding 2023 – 007: Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) Material Weakness Criteria: Non-federal entities that acquire, manage, or dispose of equipment and real property purchased with federal funds are required to establish and maintain effective internal controls and inventory procedures to ensure proper management, safeguarding, and accountability of such assets. According to 2 CFR § 200.310–200.314, non-federal entities must adequately safeguard all assets and assure that they are used solely for authorized purposes. Specifically, 2 CFR § 200.313(d) requires that property records be maintained for equipment, a physical inventory be taken at least once every two years and reconciled to the property records, and that adequate maintenance procedures be implemented to keep the property in good condition. Additionally, 2 CFR § 200.407, 200.439, 200.313, and 200.311 require non-federal entities to obtain prior written approval from the federal awarding agency or pass-through entity before using federal funds to purchase or lease equipment (with a per-unit cost of $10,000 or more), land, or buildings. Condition: During our review of the Organization’s internal controls over compliance related to the Title V major program, we noted that the Organization did not obtain prior written approval from the funding agency for the purchase of land and a building with Title V funds, with the purchase exceeding the $20,000 threshold included in the Title V contract. Additionally, the Organization did not have an approved budget that included these capital expenditures. The Organization also does not have an adequate system of controls established to identify, mark, record, or maintain equipment and real property purchased with federal funds, and no periodic physical inventory of such assets is being performed. Questioned Costs: None. Cause: The Organization does not have sufficiently established control policies and procedures to ensure that prior written approval is obtained for capital expenditures as required by federal regulations and the grant contract. The Organization also lacks established control policies for identifying, marking, recording, or maintaining equipment and real property, as well as for conducting periodic inventories. Effect: The Organization is not in compliance with federal requirements for prior written approval of capital expenditures and for equipment and real property management. As a result, there is an increased risk that federal funds may be used for unallowable purposes, and the Organization may be unable to distinguish federally funded property from other property or detect if such property is misplaced or stolen. Recommendation: We recommend that the Organization becomes familiar with the requirements of 2 CFR Part 200 and establishes appropriate internal control policies and procedures to ensure that prior written approval is obtained for all capital expenditures with federal funds. We further recommend that the Organization implement procedures for maintaining property records, conducting periodic physical inventories, and ensuring all staff are trained on these requirements. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.