Finding Text
AL 10.553, 10.555, 10.559 Child Nutrition Cluster, US Department of Agriculture, Award ID: 1603003, Award Year: July 1, 2022 ? June 30, 2022. Criteria: The non-federal entity must have and use documented procurement procedures, consistent with CFR 200.320 for any procurements exceeding the micro-purchase threshold of $10,000, and must maintain records to detail the history of procurement including (1) rationale for the method of procurement, (2) selection of contract type, (3) contractor selection or rejection, and (4) the basis for the contract price. Small purchases (between $10,000 and $250,000) require price or rate quotations from an adequate number of qualified sources. Additionally, the non-federal entity must maintain written standards of conduct covering conflicts of interest for its employees engaged in the selection, award and administration of federal contracts. Condition and context: Culver School District maintains written board policies regarding procurement, however they are not sufficiently developed to meet the requirements for federal procurement as required by CFR 200.320, described above. We identified three procurements during the fiscal year which exceeded the micro-purchase threshold of $10,000. Two of the contracts were not procured in accordance with the federal procurement requirement: one contract received only one quote, the other had no quotes. Cause: In addition to the lack of formal documentation with relation to federal procurement described above, the Nutrition Manager did not receive adequate training related to using competitive methods of procurements for large awards. Effect: Two of three procurements were awarded without evidence of employing competitive methods. Recommendation: We recommend the District revisit their procurement policies to ensure they comply with requirements related to federal procurement. Additionally, annual training should be required for all employees with federal procurement responsibilities. Views of responsible officials: The District is reviewing the current procurement policies to identify what changes are necessary to be compliant with federal guidelines on procurement. The District has also researched and selected a procurement training for the Nutrition Department to attend. The District will also be researching what trainings can be attended on an annual basis for all employees that have federal procurement responsibilities.