Finding Text
2023-004 Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.559
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number: N/A
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Qualification
Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following their procurement policy, specifically related to small purchases and one project exceeding the $250,000 threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded.
Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases and one project exceeding the $250,000 threshold. In our sample of sixteen vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for two vendors. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for two of the three vendors that were selected for testing.
Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required.
Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment.
Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services.
Repeat Finding: No
Recommendation: We recommend the District review procedures to ensure that the District's procurement policy is consistently followed.
View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.