Finding Text
2022 ? 001 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: ?200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and the School should have controls in place to ensure compliance with procurement requirements of the Child Nutrition Cluster program. Additionally, ?200.318 states that the School must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: During our audit we noted that not all of the responses for quotes and documentation of how it was determined to use a certain vendor were retained. Questioned costs: $34,399 for ALN 10.553 and 10.555 Context: 1 of 8 procurements tested was not supported by proper documentation detailing the complete history of the transaction or formal documentation of the controls in place over compliance to ensure the formal documentation of the reasoning for the procurement decision. Cause: The vendor had been used for several years, so any formal documentation of the original procurement decision to start using the vendor was no longer on file with the School. It was corroborated with multiple School staff that the School did compare prices on order guides for the year under audit to other vendors used, but there was no formal documentation of this process. Effect: Lack of proper documentation of procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: There is no disagreement with the audit finding.