Finding Text
Federal Program: U.S. Department of Agriculture passed through Missouri Department of Elementary and Secondary Education: Child Nutrition Cluster - School Breakfast Program (10.553) and National School Lunch Program (10.555). Criteria: The District should follow their own procurement policy. Additionally, the District should comply with Section 12(n) of the NSLA, 42 USC 1760(n) and Program regulations at 7 CFR section 210.21(d), which requires schools to purchase, to the maximum extent practicable, domestic commodities or products for use in meals served under the Child Nutrition Programs. Furthermore, USDA policy requires that all procurement documents - including solicitations, contracts, and purchase orders - include language mandating compliance with the Buy American provision. Condition: The District did not follow their written procurement policy when procuring food and related services greater than $50,000. Their procurement policy requires either sealed bids or proposals. The District only obtained quotes from vendors. Required Buy American language was not included in several food service vendor contracts and purchase agreements reviewed. Cause: The District was unaware that their quotes did not meet the requirements of their written procurement policy. They were also not aware that their contracts did not include the required Buy American language. Effect: By not following their written procurement policy, the District increased the risk of unallowable costs, and potentially choosing the incorrect vendor. Failure to include the Buy American clause could have resulted int he use of non-domestic products without proper justification. Questioned Costs: None. Context: Actual expenditures of the program were $816,771 during the fiscal year ended June 30, 2025. Repeat Finding: No. Recommendation: We recommend the District implement internal controls to ensure their procurement policy is followed. We also recommend updating their contracts with all required language, including the Buy American clause. Views of Responsible Officials: The District has already implemented internal controls to ensure their procurement policy is followed. They have also updated their contracts to include all required language, including the Buy American clause.