2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.
2022-002 Criteria: ?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 utilize quotes, sealed bids, or competitive proposals for certain procurements and any sole course conclusions were also not documented. Questioned Costs: ALN 10.553 and 10.555, Federal Award Identification Number 22MIN061N1199: $115,190.69 ALN 84.027 and 84.173, Federal Award Identification Number H027A210087: $302,459.82 Context: Of the two procurements tested in the Special Education Cluster, both were missing documentation to support a proper procurement method. Of 14 procurements tested in the Child Nutrition Cluster, three were missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.
2022-003 Material Weakness in Internal Controls over Compliance and Compliance Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Federal Program Name: Child Nutrition Cluster and Special Education Cluster Assistance Listing Number: 10.553, 10.555, 84.027, and 84.173 Federal Award Identification Number and Year: 22MIN061N1199 and H027A210087 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2022 Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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, 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. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over several covered transactions in fiscal year 2022. Context: Of five covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on any of the five. Of five covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications on one of the five. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.