Finding 7959 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2024-01-09
Audit: 10379
Organization: Town of Clinton (MA)

AI Summary

  • Core Issue: The Town failed to conduct a proper competitive procurement process for school lunch food products.
  • Impacted Requirements: This violates federal regulations on competition and suspension/debarment checks.
  • Recommended Follow-Up: The Town should establish procedures to ensure competitive procurements and verify vendor eligibility for all relevant purchases.

Finding Text

U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $342,999 Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.

Corrective Action Plan

The Town of Clinton/School Department will maintain proper procurement procedures in compliance with Local, State and Federal laws and regulations. State procurement laws (MGL Chapter 30B for Goods and Services and MGL Chapter 149 Construction) are followed however the district is aware of the federal requirements. When there are exemptions from state procurement laws, of when federal regulations are stricter the district will use the strictest rules, under 2 CFR 200.318-327. These procedures have been updated in the Financial Procedures Manual (pages 231-240, under Section II Procurement System). The Town of Clinton/School Department will utilize two methods to determine if a potential vendor has been suspended or disbarred. Prior to approving a requisition for a contracted service in excess of $25,000 funded by a Federal grant, district will check Sam.gov and will require the vendor to sign an affidavit. The Town of Clinton/School Department will expend membership with French River Education Center - Purchasing Cooperative to include several school lunch food products.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 7960 2022-001
    Significant Deficiency
  • 7961 2022-001
    Significant Deficiency
  • 7962 2022-001
    Significant Deficiency
  • 7963 2022-002
    -
  • 7964 2022-002
    -
  • 7965 2022-002
    -
  • 7966 2022-002
    -
  • 584401 2022-001
    Significant Deficiency
  • 584402 2022-001
    Significant Deficiency
  • 584403 2022-001
    Significant Deficiency
  • 584404 2022-001
    Significant Deficiency
  • 584405 2022-002
    -
  • 584406 2022-002
    -
  • 584407 2022-002
    -
  • 584408 2022-002
    -

Programs in Audit

ALN Program Name Expenditures
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $248,338
84.425 Education Stabilization Fund $139,635
10.553 School Breakfast Program $129,715
10.555 National School Lunch Program $62,847
84.010 Title I Grants to Local Educational Agencies $33,273
84.424 Student Support and Academic Enrichment Program $29,729
10.559 Summer Food Service Program for Children $28,908
84.048 Career and Technical Education -- Basic Grants to States $22,450
84.027 Special Education_grants to States $18,353
84.365 English Language Acquisition State Grants $10,224
97.047 Pre-Disaster Mitigation $9,575
21.019 Coronavirus Relief Fund $8,648
84.173 Special Education_preschool Grants $7,677
84.367 Improving Teacher Quality State Grants $6,117
45.310 Grants to States $2,091