2023-001- Coronavirus State and Local Recovery Funds - Food Bank Capacity Grant (ARPA) (ALN
21.027) United States Department of Agriculture, Passed through the Texas Department of
Agriculture.
Compliance - Office of Management and Budget Guidance for Grants and Agreements Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2
Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200).
Condition and Context : The Food Bank did not follow Texas Department of Agriculture's or the 2 CFR
200 required Methods of Procurement. Deviations include lack of adherence to required Formal
Procurement Methods for purchases over the simplified acquisition threshold (SAT) (advertisement
sealed bids, etc.), competitive bidding for purchases over the SAT threshold, unavailable supporting
documents demonstrating compliance with Small Purchase Procedures for purchases over the micro
purchases threshold and under the SAT, and formal procurement requirements and other instances of
noncompliance that do not rise to the level of a finding.
Recommendation : Management should take steps to ensure that the Food Bank identifies, assigns
responsibility, and adheres to procurement requirements for federal funding. If procurement
requirements for a pass through entity and grantor differ, the more restrictive requirements should be
followed.
CORRECTIVE ACTIONS: ALL purchases being made for reimbursement through Federal funding
or being handled through a pass through process with a grantor will be reviewed and signed off
for approval prior to purchase by the President and CEO of the Southeast Texas Food Bank. The
President and CEO will ensure that proper bids have been taken and reviewed following the
required guidelines set forth by the Food Bank policy updated May 2024, Federal guidelines,
and/or grantor guidelines. The more restrictive policy either Food Bank, Federal entity, or
grantor will be followed prior to purchase. All ARPA expenditures were solicited prior to 2022 by
previous management and no records exist for bid processes.
It was also noted that the CSFP boxes were not handled through policy and procedure for small
purchases. As of June 2024, there have been three bids acquired for the next years box order.