Finding 1167836 (2025-001)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2025

Accepted

2026-01-05

Audit: 379168

Organization: Redmond School District No. 2j (OR)

Auditor: SENSIBA LLP

AI Summary

Core Issue: Two vendors were used for procurements over the simplified acquisition threshold without following required competitive processes.
Impacted Requirements: Compliance with federal procurement policies under the Uniform Guidance was not met, specifically regarding formal, competitive procurement methods.
Recommended Follow-Up: The Nutrition Program Director should enforce updated departmental policies and provide annual training to ensure compliance with procurement requirements.

Finding Text

AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID: 91882, Award Year: July 1, 2024 – June 30, 2025, Compliance Requirement: I – Procurement, Suspension and Debarment. Criteria: Procurement exceeding the simplified acquisition threshold must be conducted using formal, competitive procurement methods. Condition: Two vendors provided goods or services in excess of the simplified acquisition threshold without having been procured through a competitive process. Cause: Contracts with established vendors that exceeded the simplified acquisition threshold were not sufficiently monitored to determine the status of previous procurements. Effect: Formal, competitive procurement methods were not used for two procurements exceeding the simplified acquisition threshold. Context: The error was isolated to two procurements exceeding the simplified acquisition threshold. Recommendation: We recommend the Nutrition Program Director implement departmental policies designed to comply with established District federal procurement policy to ensure that procurement complies with requirements under the Uniform Guidance. Views of responsible officials: Acknowledgement: The District is in agreement with the finding and acknowledges the failure to comply with competitive procurement requirements. Explanation: The District’s Nutrition Services Program has documented procurement procedures for the Child Nutrition Programs that fully align with 2 CFR 200 Requirement. These procedures were last reviewed and updated in August 2024 when the District Board of Directors amended the District’s public contracting rules to increase the small and intermediate procurement thresholds. The Nutrition Services Program’s procurement procedures were updated to increase the micro-purchasing threshold to $25,000 (self-certified annually) and the simplified acquisition threshold to $250,000. Unfortunately, for the two procurements noted in the finding, the Nutrition Services Program staff did not annually monitor the dollar value of the procurements and implement the appropriate competitive procurement process as required by the procurement procedures. Reference to Action: The District has established a corrective action plan for this compliance failure, including annual training and inter-departmental processes designed to mitigate the risk of failure in the future.

Corrective Action Plan

Condition: Two vendors provided goods or services in excess of the simplified acquisition threshold without having been procured through a competitive process. Corrective Action Plan: The District’s Nutrition Services Program has documented procurement procedures for the Child Nutrition Programs. These procedures were last reviewed and updated in August 2024 when the District Board of Directors amended the District’s public contracting rules to increase the small and intermediate procurement thresholds. The Nutrition Services Program’s procurement procedures were updated to increase the micro-purchasing threshold to $25,000 (self-certified annually) and the simplified acquisition threshold to $250,000. Unfortunately, for the two procurements noted in the finding, the Nutrition Services Program staff did not annually monitor the dollar value of the procurements and implement the appropriate competitive procurement process as required by the procurement procedures. To remedy this, the District will: • Require annual ODE Child Nutrition Program-sponsored procurement training, specifically one focused on the USDA’s formal procurement process, for all Nutrition Services Program employees involved in purchasing, specifically the Director of Nutrition Services and the Operations Lead. • By April 1, 2026, the Nutrition Services Program will either conduct a competitive procurement and have an agreement in place or identify an existing pricing agreement which meets the USDA procurement standards for purchases of dairy products and produce. • The Fiscal Services Department, specifically the Accounts Payable Specialist, under the supervision of the Accounting Manager, will review the aggregate total spent with each vendor of goods or services for the Nutrition Services Program with the Director of Nutrition Services to identify which procurements require evidence of competitive procurement methods. The Accounts Payable Specialist will require the appropriate evidence and documentation of the competitive procurement process or a pricing agreement for all procurements that exceed the micro-purchasing threshold of $25,000 prior to approving a purchase requisition. Name of Contact Person Responsible for Corrective Action: Lance McMurphy, Director of Nutrition Services Anticipated Completion Date: April 1, 2025

Other Findings in this Audit

1167832 2025-001

Material Weakness Repeat
1167833 2025-001

Material Weakness Repeat
1167834 2025-001

Material Weakness Repeat
1167835 2025-001

Material Weakness Repeat
1167837 2025-002

Material Weakness Repeat
1167838 2025-002

Material Weakness Repeat
1167839 2025-002

Material Weakness Repeat
1167840 2025-002

Material Weakness Repeat
1167841 2025-002

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
84.010	TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES	$1.53M
84.027	SPECIAL EDUCATION GRANTS TO STATES	$1.12M
10.553	SCHOOL BREAKFAST PROGRAM	$655,841
10.555	NATIONAL SCHOOL LUNCH PROGRAM	$237,437
84.367	SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS)	$206,883
93.778	MEDICAL ASSISTANCE PROGRAM	$94,975
84.424	STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM	$62,715
84.126	REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES	$54,181
10.559	SUMMER FOOD SERVICE PROGRAM FOR CHILDREN	$51,680
10.665	SCHOOLS AND ROADS - GRANTS TO STATES	$42,139
93.658	FOSTER CARE TITLE IV-E	$30,027
10.582	FRESH FRUIT AND VEGETABLE PROGRAM	$28,416
84.365	ENGLISH LANGUAGE ACQUISITION STATE GRANTS	$24,914
64.444	LEAD TESTING IN SCHOOL AND CHILD CARE PROGRAM DRINKING WATER	$18,960
84.196	EDUCATION FOR HOMELESS CHILDREN AND YOUTH	$15,099
84.173	SPECIAL EDUCATION PRESCHOOL GRANTS	$10,366
10.558	CHILD AND ADULT CARE FOOD PROGRAM	$3,459
45.310	GRANTS TO STATES	$1,698
84.425	EDUCATION STABILIZATION FUND	$484