Finding Text
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement Affected: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Qualification
Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment.
Questioned Costs: None
Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement
Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.