Finding Text
Criteria: Under 2 CFR 200.318, non-federal entities are required to maintain documented procurement procedures that align with applicable federal, state, and local laws. Additionally, entities must ensure that all procurements provide full and open competition and take steps to utilize small and minority businesses, women's business enterprises, and labor surplus area firms when possible.
Condition: The District's procurement policies do not comply with the federal procurement standards outlined in 2 CFR 200.318 through 200.327. Specifically, the policies lack adequate procedures to ensure full and open competition, and they do not include provisions addressing the use of small, minority-owned, and women-owned business enterprises as required by federal regulations.
Cause: The District has not updated its procurement policies to reflect current federal requirements, which were revised under the Uniform Guidance. The lack of training and resources contributed to the oversight.
Effect: Noncompliance with federal procurement standards could lead to questioned costs for expenditures under the Child Nutrition Cluster. It also incresaes the risk of noncompetitive practices and missed opportunities to engage small and disadvantaged businesses.
Questioned Costs: Unknown.
Recommendation: In order to correct the procurement process for Child Nutrition the client should revise the District's procurement policies to fully comply with 2 CFR 200.318 through 200.327, provide training for staff involved in procurement to ensure they understand and implement the updtaed policies, conduct periodic reviews of procurement activities to verify compliance with the revised policies, document efforts to engage small, minority-owned, and women-owned business enterprises in procurement activiites.
Prior Year Finding: None.
Auditee Response: See attached response.