Finding Text
2024 - 006: Procurement
Federal Agencies: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
ALN: 10.553, 10.555, 10.556, and 10.559
Federal Award Identification Number and Year: 23MIN061N1199, 2024
Pass-Through Agency: Minnesota Department of Education
Pass-Through Number: 1-0112-000
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.
Condition: The District did not retain formal documentation of controls over procurement procedures over covered transactions in the child nutrition program in 2024.
Questioned Costs: None
Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 2 of 40 items tested for the child nutrition program.
Cause: Although it was determined that compliance requirements were met through corroboration with multiple District staff and contractors as well as confirmation that one of the noted procurements in question was purchased through a group purchasing cooperation, the documentation of related controls was not formally documented or retained.
Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements.
Repeat Finding: No
Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made.
View of Responsible Official: There is no disagreement with the audit finding.