Finding Text
Finding 2023-001: Procurement
United States Department of Agriculture – Child Nutrition Cluster
United States Department of Agriculture – Child and Adult Care Food Program
Criteria: The non-federal entity must maintain records sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to, the following:
Rational for the method of procurement, selection of contract type, contractor selection or
rejection, and the basis for the contract price (2 CFR section 200.318(i)). The non-federal
entity must also establish and maintain effective internal control over the Federal award that
provides reasonable assurance that the non-federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award. These internal controls should be in compliance with guidance in “Standards for
Internal Control in the Federal Government” issued by the Comptroller General of the United
States or the “Internal Control Integrated Framework”, issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO) (2 CFR section
200.303(a)).
Condition: Records detailing which vendors were contacted, when they were contacted, and
support for the rationale in choosing the vendor, is not documented.
Questioned Costs: None
Cause: Management did not maintain a detailed history of procurement and did not
document a review process.
Effect: There is no reasonable assurance that the Organization managed the federal awards in
compliance with federal statutes, regulations, and the terms and conditions of the federal
award.
Recommendation: Purchasers should record, and keep on file, backup detailing which
vendors were contacted, when they were contacted, support for the rationale in choosing the
vendor. Management should implement a system of internal controls for this process.
Views of Responsible Parties and Corrective Action Plan: Management concurs with the
finding and will implement a process for documenting the procurement history and
establishing a system of internal controls.