Audit 299393

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. 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 covered transactions for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.