Finding Text
AL 10.555, 10.558, 10.559, 10.582 Child Nutrition Cluster, US Department of Agriculture, Award ID:
91882, Award Year: July 1, 2022 – June 30, 2023. Compliance Requirement: I – Procurement, Suspension
and Debarment.
Criteria: Procurement exceeding the micro purchase threshold must be conducted using competitive
methods.
Condition: Two vendors provided goods or services in excess of the micro purchase threshold without
having been procured through a competitive process.
Cause: The District had no formal policy in place to monitor small and emergency procurements to ensure
compliance with federal procurement requirements.
Effect: Competitive procurement methods were not used for two procurements and noncompetitive
procurement justifications were not documented.
Context: The error was isolated to two procurements exceeding the micro purchase threshold.
Recommendation: We recommend the District implement formal written policies for ensuring that
procurement is monitored at least annually to identify potential goods or services that may exceed the micro
purchase threshold during the fiscal year and require a competitive procurement method. Emergency
procurements should be documented, in writing, in order to justify the use of noncompetitive methods.
Views of responsible officials: The District’s Nutrition Services Program has previously documented
procurement procedures for the Child Nutrition Programs. These procedures were last reviewed in fall 2022
as part of a Procurement Compliance Review performed by the Oregon Department of Education. The
procedures require that the District consider the “aggregate dollar amount” of purchases of supplies or
services. Additionally, the procedures state “the Director of Nutrition Services or their designee is
responsible for the documentation of records to fully explain the decision to use the noncompetitive
negotiation” (in the case of an emergency procurement). Unfortunately, in the two instances noted in the
finding, the District did not adhere to the written procedures. Moving forward, at the close of each fiscal
year, the Fiscal Services Department will provide the aggregate total spent with each vendor of goods or
services to the Director of Nutrition Services or their designee in order to determine if any procurements
are at or near the micro- or intermediate-purchase threshold. The Director of Nutrition Services or their
designee will conduct the appropriate competitive procurement(s) in accordance with District procedures,
if necessary.