Finding Text
FINDING 2022-001: PROCUREMENT POLICY (30000, 50000)Assistance Listing #10.553 & 10.555 ? U.S. Department of Agriculture, California Department of Education,National School Lunch Program, Child Nutrition ClusterCriteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients ofStates, must follow the procurement standards set out at 2 CFR sections 200.319 and 200.320. For small purchasesunder $250,000 the entity must obtain quotations from an adequate number of qualified sources, provided that theprocurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200.For purchases over $250,000 the entity must obtain sealed bids, provided that the procurements conform toapplicable Federal statutes and the procurement requirements identified in 2 CFR part 200.Condition: The District could not provide an auditable trail to prove that it followed procurement methods for smallpurchases and purchases over $250,000. The procurement steps did not reflect the requirements identified in 2 CFRpart 200.319 and 200.320.Questioned Cost: Unknown.Context: We tested three contracts, two which were under the simplified threshold and one that requiredcompetitive bidding. The three contracts totaled $891,380.Effect: Failure to adopt a clear written policy that conforms to applicable Federal statutes and the procurementrequirements is a lack control over compliance in procurement transactions.Cause: District approved and awarded contracts but could not show that it followed procurement requirement in 2CFR 200.319 and 200.320.Recommendation: We recommend that the District follow procurement requirements identified in 2 CFR part 200when purchasing items with Federal funds.Views of Responsible Officials:The District employed an experienced Director who satisfied all of the CDE requirements, communicated with andworked well with CDE, and who typically followed all requirements. For whatever reason, this Director apparentlydid not follow the procurement requirements for 2021-22. It is possible that the Director thought therequirements were waived due to the pandemic, or possibly followed them but left no discoverable audit trail whenshe left the District in the fall of 2021. The District worked to correct this for the 2022-23 school year.