Finding Text
Federal Program: U.S. Department of Agriculture: Child Nutrition Cluster-School Breakfast Program (10.553), National School Lunch Program (10.555), and Summer Food Service Program (10.559). Criteria: When a sub-recipient of federal awards uses federal money to acquire goods and services expected to cost more than $25,000, the sub-recipient must determine if the vendor is suspended, debarred, or otherwise excluded from doing business with the federal government. Condition: The District purchased goods from three vendors totaling greater than $25,000 that required the District to determine the vendor's status with the federal government. The vendors were, in fact, not excluded parties, and the District made the determination before the disbursements were made. However, the District did not keep supporting documentation that the determination was made. Cause: The District was unaware that they needed to keep documentation of checking the vendor's status on System for Award Management (SAM). Effect: The District did comply with the federal compliance requirements. However, internal controls were such that noncompliance could occur and go undetected. Context: Actual expenditures of the program were $228,460 during the fiscal year ended June 30, 2024. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District verify a vendor's status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and to keep supporting documentation of the verification of the vendor's status. Views of Responsible Officials: The District will verify all vendor's status using the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and keep all supporting documentation.