Finding 1168240 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-01-07

AI Summary

  • Core Issue: The Sponsoring Organization failed to consistently document verification that new CACFP centers or FCC providers were not suspended or debarred before enrollment.
  • Impacted Requirements: Compliance with 2 CFR Part 180 and the USDA's National Disqualified List (NDL) is essential to avoid enrolling ineligible entities.
  • Recommended Follow-Up: Reinforce internal controls and implement a supervisory review to ensure all enrollment files have documented verification of suspension and debarment checks prior to enrollment.

Finding Text

Finding 2025-001: Suspension and Debarment Criteria: The recipient must comply with the requirements regarding Suspension and Debarment (2 CFR Part 180 and 2 CFR § 417.300), which requires that the recipient not enter into any transaction with a person or entity who is proposed for debarment, debarred, suspended, or otherwise excluded from or ineligible for participation in Federal programs or activities. For the CACFP, the USDA maintains a National Disqualified List (NDL) to facilitate this compliance. Condition: The Sponsoring Organization did not consistently document the verification that new Child and Adult Care Food Program (CACFP) centers or Family Child Care (FCC) providers were not suspended or debarred prior to enrollment. During testing of five new CACFP centers/FCC providers enrolled during the audit period, one center/FCC provider file (20% of the sample) did not contain documentation of the required verification against the USDA National Disqualified List (NDL) or other appropriate suspension/debarment verification source prior to the effective date of the enrollment agreement. Cause: Personnel responsible for the enrollment process did not consistently follow the established internal control procedure to document verification of new centers/FCC providers against the USDA National Disqualified List (NDL) prior to finalizing the enrollment. Effect: A lack of documented verification increases the risk that the Sponsoring Organization could inadvertently enroll a center or FCC provider that has been suspended or debarred from participation in Federal programs, leading to non-compliance with Federal regulations and potential loss of Federal funding. Questioned Costs: None noted. Context: This is the first year this finding has been reported. The internal control deficiency appears to be a breakdown in the execution of the established procedure rather than an absence of a control. Repeat Finding: No. This is the first time this specific finding has been identified. Recommendation: We recommend the Sponsoring Organization reinforce the established internal control procedure and implement a supervisory review to ensure that all enrollment files for new CACFP centers and FCC providers include clear, documented evidence that the suspension and debarment verification was performed and dated prior to the execution of the enrollment agreement.

Corrective Action Plan

Finding 2025-001: Suspension and Debarment Condition: The Sponsoring Organization did not consistently document the verification that new Child and Adult Care Food Program (CACFP) centers or Family Child Care (FCC) providers were not suspended or debarred prior to enrollment. View of Responsible Officials: 4C agrees with the audit finding. Corrective Action Plan: 4C will implement a control process within the onboarding process. The onboarding check list will have sign offs for the manager and strategic director over the program. Responsible Party: Pagie Runion, Strategic Director of Business Services Anticipated Completion Date: June 30, 2026

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Eligibility

Other Findings in this Audit

  • 1168239 2025-001
    Material Weakness Repeat
  • 1168241 2025-002
    Material Weakness Repeat
  • 1168242 2025-002
    Material Weakness Repeat
  • 1168243 2025-003
    Material Weakness Repeat
  • 1168244 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.558 CHILD AND ADULT CARE FOOD PROGRAM $2.04M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $493,327
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $16,520
93.434 EVERY STUDENT SUCCEEDS ACT/PRESCHOOL DEVELOPMENT GRANTS $4,386
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $4,000