Finding 1164711 (2025-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2025-12-12

AI Summary

  • Core Issue: The District failed to obtain necessary verification that a food service vendor was not suspended or debarred, which is required when using federal funds over $25,000.
  • Impacted Requirements: Compliance with 2 CFR 200.213 and 2 CFR Part 180, which mandates verification of vendor eligibility for federal contracts.
  • Recommended Follow-Up: The District should inform the procurement agent to improve procedures for verifying vendor status and seek alternative verification if documentation is missing before making purchases.

Finding Text

Reference Number: 2025-004 Program Name: Child Nutrition Cluster Description: Procurement Criteria Per 2 CFR 200.213 and 2 CFR Part 180, subpart C, when federal funds are used for contracts exceeding $25,000, the non-Federal entity must verify that vendors are not suspended or debarred by obtaining a certification, adding appropriate contract language, or checking SAM.gov. DPI School Nutrition Program procurement requirements incorporate these Uniform Guidance rules for all applicable food service procurements. Condition The District participates in a cooperative, which conducts bidding and procurement activities for food service vendors on behalf of its member districts. For one required vendor under the cooperative’s awarded contracts, the procurement agent did not obtain or document the required Suspension and Debarment verification. As a result, the District did not have evidence that the vendor had been checked against the federal suspension and debarment list prior to purchases made during the audit period. The District relies on its procurement agent for School Nutrition Program purchases and does not independently select or negotiate with vendors awarded through the cooperative. The missing documentation was related to the procurement agent’s procedures rather than the District’s internal processes. Cause The District did not perform or retain the required Suspension and Debarment verification for this vendor as part of its procurement documentation. Effect The District lacked required evidence supporting that federal Child Nutrition Program funds were not expended with a vendor that had been suspended or debarred. Questioned Costs None. There is no indication that the vendor was suspended or debarred. Recommendation We recommend the District communicate this issue to their procurement agent and request that the cooperative enhance its procurement procedures to ensure Suspension and Debarment verification is obtained and retained for all awarded vendors. The District should also obtain supplemental verification if documentation is not available from the procurement agent prior to making purchases with federal funds. Views of Responsible Officials and Corrective Action See Corrective Action Plan.

Corrective Action Plan

Reference Number: 2025-004 Description: Procurement Corrective Action Plan: The District will ensure that suspension and debarment certificates are obtained for all necessary vendors. If Certificates are not available, the District will search Sam.gov prior to doing business under a covered transaction. Contact Information: For additional information regarding this finding, please contact Ryan Bandt, Director of Business Services, at 920-675-1044.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1164707 2025-004
    Material Weakness Repeat
  • 1164708 2025-004
    Material Weakness Repeat
  • 1164709 2025-004
    Material Weakness Repeat
  • 1164710 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 SPECIAL EDUCATION GRANTS TO STATES $444,618
10.555 NATIONAL SCHOOL LUNCH PROGRAM $388,713
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $197,580
93.778 MEDICAL ASSISTANCE PROGRAM $164,709
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $80,539
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $64,386
10.553 SCHOOL BREAKFAST PROGRAM $40,299
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $36,549
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $25,792
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $23,018
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $18,274
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $1,109
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $961
84.425 EDUCATION STABILIZATION FUND $182