Finding Text
Procurement, Suspension and Debarment
U.S. Department of Agriculture/Passed-through Texas Department of Agriculture
Food Distribution Cluster
Federal Assistance Listing Number 10.565 – Commodity Supplemental Food Program
(Administrative Costs)
Award Number: TX-101-4001
Award Years: 10/1/22 – 9/30/23 and 10/1/23 – 9/30/24
Federal Assistance Listing Number 10.568 – Emergency Food Assistance Program
(Administrative Costs)
Award Numbers: TX-101-7058 and 01534
Award Years: 10/1/22 – 9/30/23 and 10/1/23 – 9/30/24
U.S. Department of Treasury/Passed-through Harris County Public Health
Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds (CSLFR) (ARPA – COVID-19)
Award Numbers: N/A
Award Years: 10/1/22 – 9/30/23 and 10/1/23 – 9/30/24
Type of Finding: Other instance of noncompliance
Criteria: Management is responsible for internal controls over compliance with Procurement, Suspension and Debarment in accordance with the Uniform Guidance.
Condition: Management has a procurement policy in place to ensure compliance with federal law and standards. However, management was unable to provide supporting documentation for a formal bidding process and verification of suspension and debarment, as required according to the procurement policy, for two vendors.
Questioned Costs: Food Distribution Cluster – $30,850; CSLFR ARPA – COVID-19 grant – $13,895
Context/Sampling: A nonstatistical sample of 3 out of 21 vendors was selected for testing the Food Distribution Cluster. A nonstatistical sample of 1 out of 3 vendors was selected for testing the CSLFR ARPA – COVID-19 grant.
Cause: The Food Bank experienced turnover in its chief financial officer, controller, and accounting manager positions during the year.
Effect or Potential Effect: Lack of compliance with Procurement, Suspension and Debarment compliance requirement may result in reduced future funding for the program.
Identification as a Repeat Finding, if applicable: 2023-003
Recommendation: We recommend The Food Bank incorporate controls and procedures to ensure the Procurement Policy is being adhered to at all times.
Views of Responsible Officials: The Food Bank agrees with the finding, which is due to turnover and transitions in key positions.
Corrective Action Plan: A vendor analysis by the Procurement department has been completed and communicated to each director to create a RFP schedule for all contract renewals. Annual education of directors and managers on the procurement policy, informal bid, and formal bid processes was completed previously and will be completed again. The team will be working with the new COO to ensure that these processes are followed and implemented frequently as new personnel is onboarded.