Finding Text
Child Nutrition Cluster - Procurement
Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster
(National School Lunch Program, School Breakfast Program, and COVD-19 Summer
School Food Service Program CFDA No. 10.555, and 10.559) passed through the New
York State Education Department.
Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own
documented procurement procedures which reflect applicable state, local, and tribal laws,
and regulations, provided that the procurements conform to applicable Federal law and
the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213
stipulates that no awards, subawards, or contracts be awarded to parties that are debarred,
suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities. Statement of Condition: During our discussions with management and testing of the
major program, we noted that the District is not verifying the eligibility of vendors to
participate in Federal assistance programs.
Statement of Cause: The District did not review compliance requirements related to
procurement outlined in 2 CFR Section 200.318 and Section 200.213.
Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The
District is not performing required procedures, as a result, vendors that are not eligible for
participation in Federal assistance programs or activities could be selected or the District
could be overpaying for goods and services.
Questioned Cost: None.
Repeat Finding: Yes
Recommendation: We recommend that the District review the requirements of 2 CFR Section
200.213 and ensure that a review of the eligibility of potential vendors to participate in
Federal assistance programs or activities is performed prior to disbursing funds to the vendor.
Views of the Responsible Officials and Planned Corrective Actions: The District is in a
contract with Capital Region BOCES for the management of the school nutrition
department. There were staff changes during the year and the new hire was unaware of
the requirements. Cathy Meher, District Treasurer will meet with both the new Director
and his supervisor at BOCES to relay the audit finding and develop a plan moving
forward. This will happen immediately.
Perspective Information: As part of testing of compliance over procurement, a selection
of vendors charged to the major program was selected for testing of compliance. Of the
District’s vendors charged to the program, none were suspended or debarred from
participation in Federal assistance programs or activities.