Finding Text
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-591029-DPI-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: During our testing of procurement transactions of the program we noted that the District was not consistently following the procurement policy, specifically requirements related to small purchases. Small purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. In addition, during our testing of suspension and debarment, we identified two vendor contracts that were entered into that did not include language related to suspension and debarment.
Questioned Costs: None
Context: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In our sample of five procurement transactions subject to small purchase requirements we noted that the District did not retain documentation of an adequate number of price quotes for two vendors selected for testing. Additionally, in our sample of two suspension and debarment transactions, the District did not verify that either vendor was not suspended or debarred before entering into the transaction.
Cause: The District did not follow their Federal Funds Procurement Policy and District controls did not properly document procurement, suspension and debarment requirements in accordance with Uniform Guidance.
Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District’s Federal Funds Procurement Policy. We also recommend the District evaluate current procedures and controls, including segregation of duties, to ensure that policies are consistently followed and properly documented in accordance with District policies.
View of Responsible Officials: There is no disagreement with the finding.