Finding Text
2024-003: Suspension and Debarment—Material Weakness
U.S. Department of Agriculture
Passed through Missouri Department of Elementary and Secondary Education
Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program)
Federal award year 2023-2024
Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year.
Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds.
Cause: A lack of controls to reasonably ensure this verification was performed.
Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding.
Questioned costs: None
Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the District had performed the required verification. None of the samples tested were identified as suspended or debarred entities.
Identification as a repeat finding, if applicable: Not applicable.
Recommendation: We recommend the District develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification.
View of responsible officials: Management agrees with this finding.