Finding Text
U.S. Department of Agriculture, Pass-Through Iowa Department of Education, Child Nutrition Cluster Program, Assistance Listing 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 National School Lunch Program-Supply Chain Assistance, 10.555 Commodities (Noncash), 10.555 Commodities-DOD (Noncash); Finding: The District did not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program until March 2023. Criteria: The April 2023 Office of Management and Budget Compliance Supplement states the following, "Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220...When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity,,,is not suspended or debarred or toherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity." Condition: The District issues a request for proposal every four years to select milka and bread vendors. The request for proposal does not require the vendors responding to the request for goods over $25,000 to provide a certificate of suspension and debarment. The District does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District does not monitor compliance with suspension and debarment rules as established by the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0. Context: The District expended approximately $133,000 with the milk and bread vendors for fiscal year 2023. Total program non-payroll expenditures were over $800,000. Identification as a repeat finding: This is a repeat finding. Recommendation: We recommend the District require bidders on contracts to provide certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by any vendor the District incurs $25,000 or more in a federal program. Response and corrective action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the District joined the Area Education Agency purchasing program for the Child Nutrition Program.