EIN: 936000535
UEI: J57VZECEUJF3
Audited by: Sensiba LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 14, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 14, 2026 (51 days ago).
What is a management decision? →FAC accepted this audit on January 14, 2025 — management decision was due July 14, 2025.
FAC accepted this audit on January 17, 2024 — management decision was due July 17, 2024.
FAC accepted this audit on January 25, 2023 — management decision was due July 25, 2023.
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 program requires that all purchases above the micro purchase threshold be procured using various competitive methods. Condition and context: Culver School District procured two vendor contracts over the micro purchase threshold without obtaining an adequate number of quotes. Cause: A new Nutrition Manager began the position during the fiscal year ended June 30, 2022 and was not provided with the proper training regarding required procurement methods. Effect: Two procurements awarded to vendors were not bid in a competitive manner. Recommendation: We recommend the District ensure training is provided to all employees with federal procurement responsibilities prior to conducting such procurement. Views of responsible officials: The District has researched and identified a training through the Oregon Department of Education, USDA and The Institute of Child Nutrition where procurement was a topic on the agenda. The Nutrition Supervisor attended this training in August of 2022. The District will also continue to look for additional procurement trainings and resources that can be attended on an annual basis for all employees involved with federal procurement responsibilities. The District has also established a contact with the Oregon Department of Education and the Oregon Child Nutrition Coalition to reach out when questions arise in regard to procurement. The District will also be reviewing vendor totals on a more frequent basis throughout the year to identify if certain vendors are nearing the micro purchase threshold and if additional quotes need to be obtained from other vendors.
Show full finding ▾Hide full finding ▴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 program requires that all purchases above the micro purchase threshold be procured using various competitive methods. Condition and context: Culver School District procured two vendor contracts over the micro purchase threshold without obtaining an adequate number of quotes. Cause: A new Nutrition Manager began the position during the fiscal year ended June 30, 2022 and was not provided with the proper training regarding required procurement methods. Effect: Two procurements awarded to vendors were not bid in a competitive manner. Recommendation: We recommend the District ensure training is provided to all employees with federal procurement responsibilities prior to conducting such procurement. Views of responsible officials: The District has researched and identified a training through the Oregon Department of Education, USDA and The Institute of Child Nutrition where procurement was a topic on the agenda. The Nutrition Supervisor attended this training in August of 2022. The District will also continue to look for additional procurement trainings and resources that can be attended on an annual basis for all employees involved with federal procurement responsibilities. The District has also established a contact with the Oregon Department of Education and the Oregon Child Nutrition Coalition to reach out when questions arise in regard to procurement. The District will also be reviewing vendor totals on a more frequent basis throughout the year to identify if certain vendors are nearing the micro purchase threshold and if additional quotes need to be obtained from other vendors.
Finding 2022-001 Condition: The auditor noted a finding in Nutrition Services in regards to procurement. Two vendor contracts were procured above the micro purchase threshold without obtaining an adequate number of quotes. A new Nutrition Supervisor started with the District in August of 2021 and was not trained on procurement procedures prior to the former Supervisors departure. Corrective Action Plan Corrective Action Planned: The District?s Business Manager and Nutrition Supervisor researched training resources available and have selected the appropriate training for the Nutrition Supervisor to attend to obtain procurement training. A contact with Oregon Department of Education and the Oregon Child Nutrition Coalition have also been established and are available for questions as they arise. The District will also review vendor purchases more frequently throughout the year to evaluate if other goods and services are close to the micro purchase threshold and would require additional quotes from vendors. The District will also be researching and identifying other procurement trainings that all staff that have federal procurement responsibilities can attend on an annual basis. Name of Contact Person Responsible for Corrective Action: Megan VerVaecke & Kelli Keiski Anticipated Completion Date: August 30, 2022. The Nutrition Supervisor attended training in August of 2022 that was put on through the Oregon Department of Education, USDA and the Institute of Child Nutrition. The District will continue to find additional trainings to keep up to date on procurement standards. Culver School District #4 PO Box 259 * 412 West E Street Culver OR 97734 Stefanie Garber, Superintendent
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.
Show full finding ▾Hide full finding ▴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.
Finding 2022-002 Condition: The auditor noted a finding in Nutrition Services in regards to procurement documentation. The District maintains written board policies regarding procurement, however they are not sufficiently developed to meet the requirements for federal procurements as required by CFR 200.320. Three procurements were identified during the fiscal year that exceeded the micro purchase threshold of $10,000. Two of the three contracts were not procured in accordance with the federal procurement requirement: one contract received only one quote, the other had no quotes. Corrective Action Plan Corrective Action Planned: The District?s Business Manager and Nutrition Supervisor researched training resources available and have selected the appropriate training for the Nutrition Supervisor to attend to obtain procurement training. A contact with Oregon Department of Education and the Oregon Child Nutrition Coalition have also been established and are available for questions as they arise. The District will also be researching and identifying other procurement trainings for all staff that have federal procurement responsibilities can attend on an annual basis. The District will also be reviewing the current procurement policies in place and identifying what needs to be updated in order for the policy to be compliant with Federal regulations. The policy will then go to the District?s Board of Directors to approve any amendments. Name of Contact Person Responsible for Corrective Action: Megan VerVaecke & Kelli Keiski Anticipated Completion Date: June 30, 2023. The Nutrition Supervisor attended training in August of 2022 that was put on through the Oregon Department of Education, USDA and the Institute of Child Nutrition. The District will continue to find additional trainings to keep up to date on procurement standards and procurement document retention. The District is also in the process of reviewing the procurement policies for compliance with Federal guidelines. An amended policy will be taken to the District?s Board of Directors within a month or two of this corrective action plan issue date.
FAC accepted this audit on January 18, 2022 — management decision was due July 18, 2022.
FAC accepted this audit on January 16, 2017 — management decision was due July 16, 2017.
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