Finding 43664 (2022-002)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-01-25
Audit: 38713
Organization: Culver School District #4 (OR)

AI Summary

  • Core Issue: Culver School District's procurement policies are not fully compliant with federal requirements, leading to improper contract awards.
  • Impacted Requirements: Contracts exceeding $10,000 lacked necessary competitive quotes and documentation as mandated by CFR 200.320.
  • Recommended Follow-Up: Revise procurement policies for compliance and implement annual training for all staff involved in federal procurement.

Finding Text

AL 10.553, 10.555, 10.559 Child Nutrition Cluster, US Department of Agriculture, Award ID: 1603003, Award Year: July 1, 2022 ? June 30, 2022. Criteria: The non-federal entity must have and use documented procurement procedures, consistent with CFR 200.320 for any procurements exceeding the micro-purchase threshold of $10,000, and must maintain records to detail the history of procurement including (1) rationale for the method of procurement, (2) selection of contract type, (3) contractor selection or rejection, and (4) the basis for the contract price. Small purchases (between $10,000 and $250,000) require price or rate quotations from an adequate number of qualified sources. Additionally, the non-federal entity must maintain written standards of conduct covering conflicts of interest for its employees engaged in the selection, award and administration of federal contracts. Condition and context: Culver School District maintains written board policies regarding procurement, however they are not sufficiently developed to meet the requirements for federal procurement as required by CFR 200.320, described above. We identified three procurements during the fiscal year which exceeded the micro-purchase threshold of $10,000. Two of the contracts were not procured in accordance with the federal procurement requirement: one contract received only one quote, the other had no quotes. Cause: In addition to the lack of formal documentation with relation to federal procurement described above, the Nutrition Manager did not receive adequate training related to using competitive methods of procurements for large awards. Effect: Two of three procurements were awarded without evidence of employing competitive methods. Recommendation: We recommend the District revisit their procurement policies to ensure they comply with requirements related to federal procurement. Additionally, annual training should be required for all employees with federal procurement responsibilities. Views of responsible officials: The District is reviewing the current procurement policies to identify what changes are necessary to be compliant with federal guidelines on procurement. The District has also researched and selected a procurement training for the Nutrition Department to attend. The District will also be researching what trainings can be attended on an annual basis for all employees that have federal procurement responsibilities.

Corrective Action Plan

Finding 2022-002 Condition: The auditor noted a finding in Nutrition Services in regards to procurement documentation. The District maintains written board policies regarding procurement, however they are not sufficiently developed to meet the requirements for federal procurements as required by CFR 200.320. Three procurements were identified during the fiscal year that exceeded the micro purchase threshold of $10,000. Two of the three contracts were not procured in accordance with the federal procurement requirement: one contract received only one quote, the other had no quotes. Corrective Action Plan Corrective Action Planned: The District?s Business Manager and Nutrition Supervisor researched training resources available and have selected the appropriate training for the Nutrition Supervisor to attend to obtain procurement training. A contact with Oregon Department of Education and the Oregon Child Nutrition Coalition have also been established and are available for questions as they arise. The District will also be researching and identifying other procurement trainings for all staff that have federal procurement responsibilities can attend on an annual basis. The District will also be reviewing the current procurement policies in place and identifying what needs to be updated in order for the policy to be compliant with Federal regulations. The policy will then go to the District?s Board of Directors to approve any amendments. Name of Contact Person Responsible for Corrective Action: Megan VerVaecke & Kelli Keiski Anticipated Completion Date: June 30, 2023. The Nutrition Supervisor attended training in August of 2022 that was put on through the Oregon Department of Education, USDA and the Institute of Child Nutrition. The District will continue to find additional trainings to keep up to date on procurement standards and procurement document retention. The District is also in the process of reviewing the procurement policies for compliance with Federal guidelines. An amended policy will be taken to the District?s Board of Directors within a month or two of this corrective action plan issue date.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $269,440
84.425 Education Stabilization Fund $161,227
32.009 Emergency Connectivity Fund Program $129,055
84.010 Title I Grants to Local Educational Agencies $122,880
10.553 School Breakfast Program $98,382
84.027 Special Education_grants to States $90,532
93.575 Child Care and Development Block Grant $39,405
10.569 Emergency Food Assistance Program (food Commodities) $23,883
84.377 School Improvement Grants $22,963
10.666 Schools and Roads - Grants to Counties $18,628
84.367 Improving Teacher Quality State Grants $18,225
84.424 Student Support and Academic Enrichment Program $17,283
84.173 Special Education_preschool Grants $3,500
10.649 Pandemic Ebt Administrative Costs $614