Finding 1156992 (2024-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369308
Organization: Town of Clinton (MA)

AI Summary

  • Core Issue: The District failed to secure individual contracts with vendors and did not fully verify suspension and debarment status, violating federal procurement rules.
  • Impacted Requirements: Non-compliance with 2 CFR sections 200.319 and 200.214 regarding competition and vendor eligibility.
  • Recommended Follow-up: The District should establish individual contracts with vendors and ensure all vendors provide required suspension and debarment certifications for future purchases.

Finding Text

2024-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The District utilized prices that were competitively procured by French River Collaborative, of which it is a member, and did not obtain individual contracts with the five vendors. Additionally, the District only obtained one of the four required suspension and debarment certifications. Cause: The District did not follow federal award policies and procedures for contract management and suspension and debarment verification when procuring school lunch goods and services. Effect: The District might not obtain the proper negotiated rates that were part of the competitive procurement. The District is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the three vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2023-001 Recommendation: The District should obtain individual contracts with vendors that were competitively procured by the Collaborative and require those vendors to attest on suspension and debarment certifications, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.

Corrective Action Plan

2024-001: Significant Deficiency in Internal Controls and Compliance Finding -Child Nutrition Cluster ALN (10.553, 10.555,10.559): A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food product. (Questioned Costs: None) The Town of Clinton/School Department will maintain proper procurement procedures in compliance with Local, State and Federal laws and regulations. When there are exemptions from state procurement laws, or when federal regulations are stricter the district will use the strictest rules, under 2 CFR 200.318-327. These procedures are included in the Financial Procedures Manual (pages 231-240, under Section II Procurement System). The Town of Clinton/School Department will obtain individual contract with vendors competitively procured by French River Collaborative, of which the district is a member. Key Control Key Actions Resources Needed Timeline Outcome Competitive Procurement Process Use appropriate resources to mitigate any errors or omissions, and maintenance of records accurately Individual Contracts, including suspension/debarment clause Cooperative Purchasing Sheets Internal Controls Guide Online Resources: Sams.gov FY24, FY25 ongoing Streamlined procurement process & internal controls for ALL funding sources Contacts: Food Services Manager & School Business Manager Submitted by Annette Colón, Business Manager MBA, MCPPO, Notary Public Clinton Public Schools 150 School St. Clinton, MA 01510 (978) 365-4200 x 12241 colona@clinton.k12.ma.us

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1156989 2024-001
    Material Weakness Repeat
  • 1156990 2024-001
    Material Weakness Repeat
  • 1156991 2024-001
    Material Weakness Repeat
  • 1156993 2024-002
    Material Weakness Repeat
  • 1156994 2024-002
    Material Weakness Repeat
  • 1156995 2024-002
    Material Weakness Repeat
  • 1156996 2024-002
    Material Weakness Repeat
  • 1156997 2024-002
    Material Weakness Repeat
  • 1156998 2024-003
    Material Weakness Repeat
  • 1156999 2024-004
    Material Weakness Repeat
  • 1157000 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $880,295
10.553 School Breakfast Program $207,723
84.010 Title I Grants to Local Educational Agencies $153,905
66.468 Drinking Water State Revolving Fund $82,699
10.555 National School Lunch Program $76,986
10.559 Summer Food Service Program for Children $60,022
84.002 Adult Education - Basic Grants to States $40,000
16.738 Edward Byrne Memorial Justice Assistance Grant Program $39,204
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $21,435
84.424 Student Support and Academic Enrichment Program $21,340
84.027 Special Education Grants to States $18,959
84.425 Education Stabilization Fund $8,927
84.365 English Language Acquisition State Grants $5,446
84.048 Career and Technical Education -- Basic Grants to States $3,200
84.173 Special Education Preschool Grants $1,167