Finding Text
2022-004 U.S. Department of Agriculture Pass-Through Iowa Department of Education Child Nutrition Cluster Program: Assistance Listing 10.553 School Breakfast Program Assistance Listing 10.555 National School Lunch Program Assistance Listing 10.555 Supply Chain Assistance Assistance Listing 10.555 Commodities (Noncash) Assistance Listing 10.555 Commodities Department of Defense (Noncash) Assistance Listing 10.559 Summer Food Service Program for Children Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,?is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? Condition: The District issues a request for proposal each year to select milk and bread vendors for the next school year. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Context: The District expended approximately $168,000 with the milk and bread vendors for fiscal year 2022. Total program non-payroll expenditures were over $800,000. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Questioned Costs: $0 Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the certification regarding suspension and debarment as outlined by the Office of Management and Budget