FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-003 – Procurement
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that the district did not document its process for concluding that procurements met the requirements of being a sole source situation.
Questioned Costs: ALN 10.555 - $19,122.61 and ALN 84.027 and 84.173 - $68,100.
Context: Of the 13 procurement transactions tested, 2 of them were considered sole source by the District but did not have the proper documentation to support the process used to determine that.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes. 2022-001.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will implement procedures to document its rationale for the procurement method used.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.
FINDING: 2023-004 – Suspension & Debarment
Federal Agency: U.S. Department of Agriculture & U.S. Department of Education
Federal Program: Child Nutrition Cluster & Special Education Cluster
CFDA Numbers: 10.555 & 84.027 and 84.173
Pass Through Agency: Minnesota Department of Education
Pass Through Number: 01-0276-000-000, H027A220087, H027X210087, H173A220086, and H173X210086
Award Periods: Fiscal year ended June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or Specific
Requirement: 2 CFR §180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that the entity, as defined in 2 CFR section §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In our testing of the programs, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the programs, it was noted that three of the seven contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s procedures do not contain sufficient guidelines for ensuring all covered transactions are verified for suspension and debarment requirements and that supporting documentation is retained.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: No.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of Responsible
Official: There is no disagreement with the audit finding. The District will document its verification of suspension and debarment before entering into covered transactions.