Finding 1173684 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-02-16
Audit: 387385
Auditor: APRIO LLP

AI Summary

  • Core Issue: The organization did not follow its own procurement policies, failing to obtain competitive quotes or justify sole-source selections.
  • Impacted Requirements: This violates 2 CFR 200.318(a) and 2 CFR 200.319(a), which mandate documented procurement procedures and full competition.
  • Recommended Follow-Up: Train staff on procurement policies and ensure accountability for compliance with competitive quoting and justification requirements.

Finding Text

Finding Reference Number: 2025-001 Procurement. Title and CFDA Number of Federal Program: Child Nutrition Cluster [10.553/10.555/10.559/10.582] Award Number: 25N1199/24L1603 Type of Finding: Federal Award Finding Finding Resolution Status: In Process. Criteria: Under 2 CFR 200.318(a), non-Federal entities must maintain and use documented procurement procedures that are consistent with applicable laws and regulations. Additionally, 2 CFR 200.319(a) requires that all procurement transactions be conducted to provide full and open competition. Statement of Condition: During our audit, we noted that the organization did not follow its documented procurement policies for a vendor. Specifically, procurements were made without proper competitive price quotes or justification for sole-source selection, and documentation supporting contractor selection and price reasonableness was missing. Cause: Although the Organization has a formal procurement policy outlining requirements for competitive quotes and single-source justifications in accordance with 2 CFR §200.320, these procedures were not followed for the transactions tested. Effect or Potential Effect: Failure to obtain competitive quotes or document single-source justifications increases the risk of noncompliance with federal procurement requirements and may result in unallowable costs being charged to the federal program. Questioned costs - None identified. Reportable Views of Responsible Officials: See Corrective Action Plan Identification of Repeat Findings - This is not a repeat finding. Recommendation: We recommend the Organization ensure that its procurement policy is fully implemented. Staff should be trained and held accountable for obtaining competitive price or rate quotations for all purchases exceeding the micro-purchase threshold, or for documenting appropriate single-source justifications when applicable.

Corrective Action Plan

The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthened to ensure consistent application of procedures and oversight. Anticipated Completion Date: 5/31/2026. Responsible Contact Person: Anthony Daniels-Halisi, CEO.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1173680 2025-001
    Material Weakness Repeat
  • 1173681 2025-001
    Material Weakness Repeat
  • 1173682 2025-001
    Material Weakness Repeat
  • 1173683 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $609,170
10.553 SCHOOL BREAKFAST PROGRAM $217,589
84.027 SPECIAL EDUCATION GRANTS TO STATES $164,005
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $43,674
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $34,753
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $32,516
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $16,329
10.555 NATIONAL SCHOOL LUNCH PROGRAM $14,827
84.425 EDUCATION STABILIZATION FUND $7,338
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $2,287