Finding Text
Significant Deficiency/ Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Repeat Finding: No Criteria: 2 CFR §200.302 - Financial Management requires funds to be expended and accounted for the federal award in accordance with state laws and procedures for expending and accounting for state funds which includes the "Accounting Manual for School Districts" by the Mississippi Department of Education which emphasizes that one of the most important aspects of controls over expenditures is an efficient and effective system of purchasing. The objectives of an effective purchasing system are to buy materials, supplies, commodities, and services that are of the right quality, quantity, price and from the right source with delivery being at the right place. These objectives should be accomplished in accordance with management's purchasing policies and in accordance with applicable federal and state purchasing laws. Each school district shall adopt purchasing policies and establish a purchasing system which will meet these objectives. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 214 states that recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR 180. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: • Several instances where the paid invoices exceeded the purchase order amount, which included instances where purchase orders were prepared for one dollar. • Several instances where certifications from SAM.gov were not obtained and included in the paid invoice packet to document that the District had verified that the vendor was not suspended or debarred. Context/Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that purchase orders are prepared for accurate amounts where required and that written certifications are obtained to ensure that vendors have not been suspended or debarred. We specifically recommend that verifications from SAM.gov be obtained by printing or saving the “No Matches Found” page to a pdf and attaching it to the paid invoice packet or procurement file. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.