Finding Text
2023-002 – Suspension and Debarment
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Procurement, Suspension and Debarment).
Program. Child Nutrition Cluster; U.S. Department of Agriculture; Assistance Listing Numbers 10.553, 10.555 and 10.559; Passed through Michigan Department of Education (MDE); All project numbers.
Criteria. Recipients of federal awards are required to follow their own internal purchasing policies, as well as complying with purchasing standards set forth in the Uniform Guidance. Part of that guidance requires an entity to check if a vendor is suspended or debarred before entering into a contract.
Condition. The District did not do checks on Sam.gov for one of the three vendors over the limit for 2022-23. The other two selected were bid by MDE or the Macomb Intermediate School District.
Cause. Despite the District having policies in place, this condition was the result of not applying these policies consistently throughout the year.
Effect. The District is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the District's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs, and the vendors in question were not actually suspended or debarred.
Recommendation. We recommend that the District consistently apply their documented procurement policy and implement procedures to provide reasonable assurance that the District does not do business with vendors that are under federal exclusions.
View of Responsible Officials. The District will develop a vendor approval process that includes verification through Sam.gov.
Responsible Official. Frank Thomas, Director of Business and Human Resources, and Margaret Sawyer, Accountant
Anticipated Completion Date. Immediately