Finding Text
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.