Finding Text
Federal Agency: US Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.559
Federal Award Identification Number and Year: Unknown
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matter
Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample.
Questioned Costs: None
Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample.
Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status.
Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds.
Repeat Finding: No.
Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction.
View of Responsible Officials: There is no disagreement with the audit finding.