Finding Text
Finding 2024-001: Procurement (50000)
Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education,
Child Nutrition Cluster
Repeat Finding? No
Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented
procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the
acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where
the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition
threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined
appropriate by the non-Federal entity.
For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following
procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the
competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive
proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are
met, in accordance with 2 CFR section 200.320(c)).
Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The
district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors.
Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold.
Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive
bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper
procurement procedure for either method in one of three instances for $751,360.
Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is
maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases
are awarded after a reasonable number of quotes have been obtained.
Context: Deficiency was noted in two of four vendors tested.
Questioned Cost: $804,492 in awarded contracts.
Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures.
Recommendation: We recommend that the District train and implement the required federal procurement procedures
to ensure that the District is in compliance.
Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year,
and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid
should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct
a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation.
To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal
bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a
shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and
ensure compliance with procurement requirements moving forward.
The live Google document will include key information such as bid solicitation dates, contract dates, and renewal
dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director
will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in
compliance with federal procurement procedures.