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: The District failed to identify that two contracts, previously procured using competitive methods, had expired and should have been competitively procured prior to purchasing food supplies from the vendors during the fiscal year ended June 30, 2025. Condition: Two vendors provided goods or services in excess of the simplified acquisition threshold without having been procured through a competitive process. Cause: The District policies include established formal written policies related to federal program procurement methods, which are consistent with requirements in the Uniform Guidance, however the Nutrition Department did not effectively implement the policies within the department. Effect: Competitive procurement methods were not used for two procurements that required formal competitive procedures, including public solicitation, evaluation based on their criteria and documentation of the process. Context: The error was isolated to two procurements exceeding the simplified acquisition threshold. Recommendation: We recommend the Nutrition Program Director implement monitoring activities relative to District federal procurement policy to ensure that methods of procurement are performed consistent with the 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 in accordance with 2 CFR 200 and District policy. 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 control over compliance failure, including annual training and inter-departmental processes designed to mitigate the risk of failure in the future. Responsible Official: Lance McMurphy, Director of Nutrition Services, lance.mcmurphy@redmondschools.org