Finding Text
Finding 2025-001: United States Department of Agriculture, Child Nutrition Cluster, Assistance Listing 10.555,10.559,10.553, 10.582. Passed through by Oregon Department of Education. Compliance requirement: Methods of procurement. Criteria: Uniform Guidance requires non‑Federal entities to maintain written procurement procedures that comply with applicable federal regulations, including methods of procurement, competition requirements, conflict‑of‑interest standards, and documentation expectations. These written procedures must be consistently followed and updated to reflect current federal requirements. Condition and Context: The District did not maintain written procurement policies as required by the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Existing policy reflects state law and does not include the procurement standards outlined in 2 CFR 200.317–200.327. Cause: The District’s procurement policies are designed to be consistent with state law. Effect: Without written federal procurement policies, the District is at increased risk of noncompliance with federal procurement standards. Recommendation: The District should develop, adopt, and maintain written procurement policies that fully align with Uniform Guidance requirements. Policies should be reviewed at least annually and updated as federal regulations change. Views of Responsible Officials: The District concurs with the finding that procurement policies did not fully comply with Uniform Guidance. Policies were based on state law, and staff turnover and limited federal procurement training contributed to the deficiency. All purchases were fair and reasonable; no waste or abuse occurred. Procurement policies have been updated to align with 2 CFR 200 standards, all procurement staff have been trained on Uniform Guidance requirements, and standardized procurement checklists and templates have been implemented to ensure documentation of cost analysis and vendor selection.