Finding Text
Finding 2025-003: Significant Deficiency - Internal Control and Compliance Over Procurement Program: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Repeat of Prior Year Finding 2024-003 Criteria: Guidance provided in 2 CFR part 200.318 requires non-federal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. A system of internal controls should be in place to ensure procurement policies are being adhered to. There are also requirements to verify the vendors are not suspended or debarred, and per the District's procurement policy, multiple quotes or bids should be obtained. Condition/Context: For one of the two contracts tested, the District was unable to provide evidence that the District's procurement policy was followed. The food service director handled the procurement with no evidence retained documenting: 1) prior approval of the equipment purchase, 2) the District's bid/quote procedures were followed, and 3) the District's policy to verify the vendor is not debarred or suspended was followed. The sample was not a statistically valid sample. Cause: The District's policy for procurement was not effectively communicated to staff or enforced. Effect: This could potentially lead to higher costs for the food service program or selection of vendors who are not eligible to be paid with federal funds. Questioned Costs: None noted. Recommendation: The District should communicate with personnel to ensure they are familiar with and complying with the District's policies regarding procurement, suspension and debarment rules for federal programs. Views of Responsible Officials: Management agrees with finding 2025-003 and will make efforts to implement recommended procedures.