Finding 1201132 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-30

AI Summary

  • Core Issue: The organization did not follow its own procurement policy by failing to obtain the required number of written bids for purchases, leading to potential noncompliance with federal guidelines.
  • Impacted Requirements: The procurement policy mandates three to five bids based on purchase amounts, and UGG requires full competition and proper documentation of vendor selection.
  • Recommended Follow-up: Management should enhance procurement controls to ensure compliance with bidding requirements and monitor vendor purchases collectively to avoid splitting procurements.

Finding Text

2025-001 – Noncompliance with Competitive Bidding Requirements – Significant Deficiency Federal Assistance Listing Number (“FALN”): 10.558 Name of Program or Cluster: Child and Adult Care Food Program Federal Agencies: Department of Agriculture Pass-through Entities: New York State Department of Health (10.558) Compliance Requirement: Procurement and Suspension and Debarment Condition The organization did not obtain the required number of written bids in accordance with its procurement policy. Fewer bids than required were obtained or documentation supporting the solicitation and receipt of bids was not maintained. Additionally, multiple purchases were made from the same vendor for similar goods or services during the fiscal year, and the aggregate amount exceeded thresholds requiring competitive bids; however, documentation did not demonstrate that these purchases were evaluated collectively for procurement purpose. Criteria The Settlement’s procurement policy requires three written bids for purchases between $5,000 and $25,000 and five written bids for purchases exceeding $25,000 but not exceeding $100,000. A public solicitation of a minimum of five bids must be conducted for purchases that exceed $100,000 Additionally, Uniform Grant Guidance (“UGG”) (2 CFR 200.318–200.320) requires procurements to be conducted in a manner providing full and open competition and requires entities to maintain records sufficient to detail the procurement history, including the basis for vendor selection. UGG also prohibits splitting procurements to avoid competition requirements. Cause Procurement procedures were not consistently followed due to inadequate review and oversight controls to ensure compliance with established bidding requirements and documentation standards. Effect Failure to obtain the required number of bids may limit competition and increases the risk that purchases are not made at the most advantageous price. It may also result in noncompliance with internal procurement policies and UGG requirements, which could lead to questioned costs. Questioned Costs None Context No questioned costs were identified as the goods and services were received and costs appeared reasonable and allowable. Recommendation Management should strengthen procurement controls by ensuring that the required number of written bids are obtained and documented in accordance with procurement policy. Management should also implement procedures to monitor purchases from the same vendor to ensure related procurements are evaluated collectively and comply with competitive bidding requirements. Views of Responsible Officials See Corrective Action Plan in Appendix 1.

Corrective Action Plan

2025-001: Noncompliance with Competitive Bidding Requirements. The planned corrective action: Immediate: By 4/30/2026, the Managing Director of Finance, the Director of Accounts Payable and Purchasing, and the CFO will meet with all program managers and review the current purchasing policies and the corresponding documentation required for submission for payment. A checklist for easy reference will be provided to all relevant requestors and approvers. Medium Term: Over the course of FY26, the CFO has been working with finance managers to review and update payment software, payment methods and financial policies. Updates will be rolled out for approval and implementation by 6/30/2026. There will also be formal communication and training provided to finance and program managers. The name(s) of the contact person(s) responsible for corrective action: Lisa Stein, CFO Julia Kagan, Managing Director, Finance Virginia Viloria, Director, Accounts Payable and Purchasing The anticipated completion date for the corrective action. 6/30/2026

Categories

No categories assigned yet.

Other Findings in this Audit

  • 1201130 2025-001
    Material Weakness Repeat
  • 1201131 2025-002
    Material Weakness Repeat
  • 1201133 2025-002
    Material Weakness Repeat
  • 1201134 2025-003
    Material Weakness Repeat
  • 1201135 2025-003
    Material Weakness Repeat
  • 1201136 2025-003
    Material Weakness Repeat
  • 1201137 2025-003
    Material Weakness Repeat
  • 1201138 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.044 TRIO TALENT SEARCH $647,024
93.569 COMMUNITY SERVICES BLOCK GRANT $439,098
10.558 CHILD AND ADULT CARE FOOD PROGRAM $331,421
93.600 HEAD START $239,134
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $146,404
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $144,137
93.667 SOCIAL SERVICES BLOCK GRANT $93,512
45.024 PROMOTION OF THE ARTS GRANTS TO ORGANIZATIONS AND INDIVIDUALS $40,000
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $21,285
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $15,217
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $3,682