Finding Text
FA 2022-001 Strengthen Controls over Expenditures
Compliance Requirements: Activities Allowed or Unallowed
Allowable Costs/Cost Principles
Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199 (Year: 2022)
Questioned Costs: $21,440
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $2,662,705 were expended and reported on the Harris County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards
pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance),
Section 200.303 – Internal Controls.
Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement
Standards state in part that “(a) the non-Federal entity must use its own documented procurement
procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal
entities must maintain oversight to ensure that contractors perform in accordance with the terms,
conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in
the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance
for procurement through small purchase procedures and state “If small purchase procedures are used,
price or rate quotations must be obtained from an adequate number of qualified sources.”
Condition:
A sample of 28 procurement transactions was randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. The following deficiencies were noted:
• For three expenditures, evidence of review and approval was not reflected within the voucher package.
• The appropriate procurement method was not used for the dollar amount and conditions associated with one procurement transaction that should have been considered a simplified acquisition transaction. Therefore, the School District could not provide evidence that an adequate number of sealed bids were sought and obtained from qualified sources.
Questioned Costs:
Upon testing a sample of $130,284 in procurement transactions, known questioned costs
of $21,440 were identified for expenditures that did not follow the School District’s procurement procedures. Using the total sample population of $518,395 in procurement transactions, we project the likely questioned costs to be approximately $85,310. The following Assistance Listing Numbers were affected by known and likely questioned costs: 10.553 and 10.555.
Cause:
The School District did not follow its policies and procedures that govern the procurement process for federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to appropriately implement procedures to address procurement compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that required procurement methods are properly identified and followed and required procurement documentation is properly safeguarded and retained. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with the finding.