Finding Text
2022-014: U.S. Department of Agriculture Passed through State of Nevada Department of Agriculture Child Nutrition Cluster: National School Lunch Program, 10.555 U.S. Department of Education Passed through State of Nevada Department of Education Charter Schools, 84.282 Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listings 10.555 and 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non-federal entity must use its own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. In addition, Uniform Guidance requires contracts contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: The School has policies and procedures which make reference to state regulation and law, but the policies have not been updated with sufficient clarity and detail to ensure compliance with federal law and standards. In addition, the contract provisions under the Federal Water Pollution Control Act as described in Appendix II to Part 200 were not included in a contract as required. Cause: The School did not have adequate internal controls to review its policy and procedures to include federal procurement requirements and ensure contracts contained all required provisions. Effect: The School may follow its documented procurement policies and not identify non-compliance with federal procurement law in cases where federal procurement law is more restrictive. In addition, contractors may not be aware of required terms and conditions. Questioned Costs: None noted Context/Sampling: Child Nutrition Cluster, 10.555 and Charter Schools, 84.282 The School?s procurement procedures were examined in their entirety. Child Nutrition Cluster, 10.555 The one applicable contract was selected for testing and was missing one of the required contract provisions. Repeat Finding from Prior Year: No Recommendation: We recommend the School review its procurement policy and include federal procurement requirements and ensure contracts contain all required provisions. Views of Responsible Officials: Management agrees with this finding.