Finding Text
Federal Agency: United State Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, and 10.556 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2022-592605-DPI-NSL-547 Award Period: 07/01/2021 ? 06/30/2022 Compliance Requirement Affected: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matter Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement outlines various purchasing methods, thresholds and requirements including, but not limited to, guidance with regards to when a non-federal entity is required to obtain rate quotations and sealed bids. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The District does not have a procurement policy that meets the requirements of the Uniform Guidance. In addition, while the District does have a policy in place related to suspension and debarment, we noted that the District is not following the policy. Context: During our testing of procurement transactions of the program we noted that District is not following federal procurement requirements and that the District policy does not follow Uniform Guidance procurement thresholds. In our testing of suspension and debarment, we noted that the District is not retaining documentation related to verification of suspension and debarment. In our sample of three covered transactions subject to suspension and debarment, we noted that the District did not retain documentation for two of the covered transactions. Cause: The District has not implemented procurement policies that meet the requirements of the Uniform Guidance. In addition, while the District does have a written policy related to suspension and debarment, the policy was not being followed. Effect: Implementing and consistently following procurement policies that meet the requirements of Uniform Guidance are required and are designed to ensure fiscal responsibility, objective contractor performance and elimination of unfair competitive advantage while spending federal funds. Additionally, not verifying that an entity is debarred or suspended could result in entering into covered transactions with debarred or suspended vendors. Recommendation: We recommend the District review and update the procurement and suspension and debarment policies. We also recommend that the District ensure that approved policies that meet federal requirements are consistently followed. Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the finding. Management will review and update the procurement policy in to be in compliance with Uniform Guidance.