Finding Text
Program: Child Nutrition Cluster CFDA Number: 10.555, 10.553 Federal Agency: U.S. Department of Agriculture Pass-through: California Department of Education Award Year: 2021-2022 Compliance Requirement(s): Procurement, Suspension, and Debarment Type of Finding: Material Weakness, Instance of Noncompliance Criteria Per the 2 CFR 200.318(a), non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.327. The non-Federal entity must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200 (Uniform Guidance). Condition As a result of the test work performed over the procurement, suspension, and debarment compliance requirements, we identified that the District?s written procedures for procurement of goods or services did not fully conform with the procurement requirements identified in 2 CFR section 200.318 through 200.327. Questioned Costs None reported Context Although the District?s purchasing policy incorporated portions of 2 CFR, sections 200.318 through 200.327, the written procedures do not conform to the requirements of 2 CFR, section 200.318(a) which requires that the non-federal entity must have and use documented procedures consistent with the standards identified in sections 200.318 through 200.327. The District?s written procedures do not identify the applicable requirements of sections 200.318 through 200.327 that apply to the procurement action based on the method of procurement. Effect The District?s written policies and procedures did not comply with the requirements of 200.318(a). Cause The District?s written policy and procedures for purchasing were not updated to incorporate the applicable requirements of sections 200.318 through 200.327 that apply to the procurement action based on the method of procurement. Repeat Finding No Recommendation We recommend that the District continue to strengthen its written procurement procedures to incorporate the applicable requirements identified in sections 200.318 through 200.327 of the Uniform Guidance that apply based on the procurement action and the method of procurement as required by section 200.318(a). Views of Responsible Officials Management agrees with the finding.