Finding Text
US Department of Agriculture
Passed through Nebraska Department of Education
Federal Financial Assistance Listing #10.558
Child and Adult Food Care Program (CACFP)
Applicable Federal Award Number and Year – 28-1183-000 7/1/2022 6/30/2023 and 7/1/2023 – 6/30/2024
Procurement, Suspension and Debarment
Material Weakness in Internal Control Over Compliance
Material Noncompliance
Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award.
Condition: The Organization entered into purchase agreements with two vendors without complying with their purchasing and procurement policies and did not follow their internal policies related to debarment and suspension.
Cause: The Organization did not seek competitive bids for purchase agreements that met the requirements of the Organization’s procurement policy. The Organization also did not document verification that vendors utilized were listed on the General Services List of Parties Excluded from Federal Procurement or Non-procurement programs.
Effect: Purchases were made by the Organization with federal grant funds that did not follow the procurement policies in place by the Organization. Also, contracts may have been entered into with parties that may have been debarred or suspended from federal procurement programs.
Questioned Costs: None reported
Context: We selected a sample of purchases made by the Organization subject to the
procurement compliance requirement, and noted that two purchase agreements, which accounted for $543,031 of amounts expended for the program were not subjected to a competitive bid process.
Repeat Finding from Prior Years: No
Recommendation: The Organization should review its procedures and controls over compliance with its purchasing and procurement policies to ensure compliance with the Procurement, Suspension, and Debarment compliance requirements of the Uniform Guidance.
Views of Responsible Officials: Management is aware of the deficiency in internal control and compliance with its procurement policies. Management is in the process of reviewing its existing purchasing and procurement policies and controls over the administration of those policies to ensure compliance with Uniform Guidance requirements.