Finding 1152975 (2023-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
$1
Year
2023
Accepted
2025-09-15
Audit: 366283
Auditor: Rsm US LLP

AI Summary

  • Core Issue: Missing vendor selection forms for small purchases led to inadequate procurement documentation.
  • Impacted Requirements: Non-compliance with Uniform Guidance and SHNLFB’s procurement policy increases risk of oversight actions.
  • Recommended Follow-Up: SHNLFB should enhance procurement procedures and maintain proper documentation to align with regulations.

Finding Text

Item 2023-005: Procurement Identification of federal programs: Food Distribution Cluster, Assistance Listing Number 10.565, 10.568, and 10.569 Federal award grant number: 204645, 203684, and 229353 Federal agency: U.S. Department of Agriculture Pass-through entity: Minnesota Department of Health and Minnesota Department of Human Services Criteria: The Uniform Guidance (2 CFR 200.320) and SHNLFB’s procurement policy require that micro-purchases may be awarded without soliciting competitive quotations if SHNLFB considers the price to be reasonable and small purchases require price or rate quotations to be obtained from an adequate number of qualified sources. Condition: During our testing of procurement requirements, we noted that for two of the small purchase disbursements selected for testing, there was no vendor selection form. The vendor selection form identifies the price and the method selected as well as requires review and approval. Without the form, the procurement documentation does not exist for small purchase disbursements. Cause: The exceptions noted above were due to a breakdown in SHNLFB’s procedures to ensure that all procurements of goods and services are in accordance with the Uniform Guidance and its procurement policy. Effect: Improper procurement procedures can result in actions taken by oversight agencies which could impact future funding. Questioned costs: $49,118 Context: The population subject to procurement requirements included 60 micro-purchase vendors and nine small purchase vendors. The sample size of six micro-purchase procurements and two small purchase procurements was determined using the guidance in the AICPA Audit and Accounting Guide—Government Auditing Standards and Single Audits. Repeat finding: Yes Recommendation: SHNLFB should continue to improve its procedures to ensure that all procurements of goods and services are in accordance with the Uniform Guidance and its procurement policy. It is also recommended that support documenting the procurements be maintained. Views of responsible officials of the auditee: SHNLFB concurs with this finding and a response is included in the corrective action plan.

Corrective Action Plan

SHLNFB will draft a “Federal Grants Management Policy Manual” and implements related procedures which will be in compliance with Uniform Guidance (2 CFR 200.320) for micro-purchases. As of April 2025, there is a Procurement Policy in place and contracted vendors and staff are required to follow the policy. For food purchases that are in relation to federal funding, due to multiple smaller purchases, the requester must obtain 3 quotes and complete a spreadsheet indicating why the vendor was selected. It is then approved by the Director of Operations to move forward with the purchase.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1152943 2023-003
    Material Weakness Repeat
  • 1152944 2023-004
    Material Weakness Repeat
  • 1152945 2023-005
    Material Weakness Repeat
  • 1152946 2023-006
    Material Weakness Repeat
  • 1152947 2023-007
    Material Weakness Repeat
  • 1152948 2023-003
    Material Weakness Repeat
  • 1152949 2023-004
    Material Weakness Repeat
  • 1152950 2023-005
    Material Weakness Repeat
  • 1152951 2023-006
    Material Weakness Repeat
  • 1152952 2023-007
    Material Weakness Repeat
  • 1152953 2023-003
    Material Weakness Repeat
  • 1152954 2023-004
    Material Weakness Repeat
  • 1152955 2023-005
    Material Weakness Repeat
  • 1152956 2023-006
    Material Weakness Repeat
  • 1152957 2023-007
    Material Weakness Repeat
  • 1152958 2023-003
    Material Weakness Repeat
  • 1152959 2023-004
    Material Weakness Repeat
  • 1152960 2023-005
    Material Weakness Repeat
  • 1152961 2023-006
    Material Weakness Repeat
  • 1152962 2023-007
    Material Weakness Repeat
  • 1152963 2023-003
    Material Weakness Repeat
  • 1152964 2023-004
    Material Weakness Repeat
  • 1152965 2023-005
    Material Weakness Repeat
  • 1152966 2023-006
    Material Weakness Repeat
  • 1152967 2023-007
    Material Weakness Repeat
  • 1152968 2023-003
    Material Weakness Repeat
  • 1152969 2023-004
    Material Weakness Repeat
  • 1152970 2023-005
    Material Weakness Repeat
  • 1152971 2023-006
    Material Weakness Repeat
  • 1152972 2023-007
    Material Weakness Repeat
  • 1152973 2023-003
    Material Weakness Repeat
  • 1152974 2023-004
    Material Weakness Repeat
  • 1152976 2023-006
    Material Weakness Repeat
  • 1152977 2023-007
    Material Weakness Repeat
  • 1152978 2023-003
    Material Weakness Repeat
  • 1152979 2023-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.565 Commodity Supplemental Food Program $234,668
10.569 Emergency Food Assistance Program (food Commodities) $216,355
21.027 Coronavirus State and Local Fiscal Recovery Funds $42,484
10.568 Emergency Food Assistance Program (administrative Costs) $9,612