Finding Text
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.318 (a), a non-Federal entity must "have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327.? Condition: An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.