Finding Text
2024-005 - Lack of Documentation for Vendor Selection
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Procurement, and Suspension and Debarment).
Program. Child Nutrition Cluster; U.S. Department of Agriculture; Assistance Listing Numbers 10.553, 10.555, 10.559 and 10.582; Passed through Michigan Department of Education (MDE); All project numbers.
Criteria. A recipient of federal awards is required to follow their own internal procurement policies, and to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the government. Suspension and debarment procedures are required whenever the amount disbursed to a single vendor in a given fiscal year is expected to be at least $25,000.
Condition. Management was not able to provide us with documentation of the procurement process or evidence of checking for suspension and debarment for two of the three vendors selected for testing.
Cause. The cause of this condition appears to be that Management was not fully versed in the requirements related to procurement, and suspension and debarment.
Effect. As a result of this condition, the District was exposed to the risk that disbursements of federal awards could be made to vendors suspended or debarred by the federal government. The District also did not fully comply with the requirements of the Uniform Guidance.
Questioned Costs. No costs are required to be questioned as a result of this finding as none of the vendors involved were actually suspended or debarred.
Recommendation. We recommend that the District implement policies and procedures to assure that documentation is retained related to compliance with internal procurement policies. We further recommend that the District implement a procedure that requires all vendors, expected to be paid more than $25,000 , be checked for active exclusions at www.sam.gov.
View of Responsible Officials. We concur with the audit assessment regarding this matter.