Finding Text
Child and Adult Care Food Program - Procurement
Information on Federal Program: U.S. Department of Agriculture Child and Adult Care Food Program (Federal Assistance Listing Number 10.558) passed through the New York State Department of Health.
Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Statement of Condition: During our discussions with management, we noted that the Organization is not following its procurement procedures for the Child and Adult Care Food Program purchases and it is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis.
Statement of Cause: The Organization did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213.
Statement of Effect: The Organization is not in compliance with 2 CFR Section 200.213. The Organization is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the Organization could be overpaying for goods and services.
Questioned Costs: None.
Perspective Information: As part of the required procurement testing, a review of a sampling of the vendors charged to the Child and Adult Care Food program and therefore represented purchases with federal dollars was performed. Of the Organization’s vendors charged, none selected were suspended or debarred from participation in Federal assistance programs or activities.
Recommendation: We recommend that the Organization review the requirements of 2 CFR Section 200.213 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor.
Views of responsible officials and planned corrective actions: Brightside Up, Inc. will review the procurement policy and document considerations for any vendors that meet the thresholds and make sure they are in compliance under Sam.gov.