Audit 327202

Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 7 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 7 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 7 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 7 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: S425U220045, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 8 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: S425U220045, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 8 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: S425U220045, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 8 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: S425U220045, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 8 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 26 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 26 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 26 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 26 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: 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 2 out of 2 covered transactions in fiscal year 2023. Context: Both of the covered transactions which were tested did not have documentation that the District performed the required verifications. Questioned Costs: None Cause: The District policy did not formalize the District’s suspension and debarment procedures. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over suspension and debarment to ensure that all covered transactions are properly verified to not be suspended or debarred such that a third party can clearly see and understand the detailed history of the procurement. Additionally, it is recommended the District formalize its procedures in a written policy. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: 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 2 out of 2 covered transactions in fiscal year 2023. Context: Both of the covered transactions which were tested did not have documentation that the District performed the required verifications. Questioned Costs: None Cause: The District policy did not formalize the District’s suspension and debarment procedures. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over suspension and debarment to ensure that all covered transactions are properly verified to not be suspended or debarred such that a third party can clearly see and understand the detailed history of the procurement. Additionally, it is recommended the District formalize its procedures in a written policy. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: 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 2 out of 2 covered transactions in fiscal year 2023. Context: Both of the covered transactions which were tested did not have documentation that the District performed the required verifications. Questioned Costs: None Cause: The District policy did not formalize the District’s suspension and debarment procedures. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over suspension and debarment to ensure that all covered transactions are properly verified to not be suspended or debarred such that a third party can clearly see and understand the detailed history of the procurement. Additionally, it is recommended the District formalize its procedures in a written policy. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: 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 2 out of 2 covered transactions in fiscal year 2023. Context: Both of the covered transactions which were tested did not have documentation that the District performed the required verifications. Questioned Costs: None Cause: The District policy did not formalize the District’s suspension and debarment procedures. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over suspension and debarment to ensure that all covered transactions are properly verified to not be suspended or debarred such that a third party can clearly see and understand the detailed history of the procurement. Additionally, it is recommended the District formalize its procedures in a written policy. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards be supported by a system of internal control to maintain adequate documentation to support costs charged to the Federal award. Condition: During our testing of a sample of non-payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted one disbursement for which the District had no supporting documentation. Questioned Costs: $1,185.55 Cause: The District was unable to locate any documentation over this transaction. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls to ensure supporting documentation for all transactions is adequately maintained and properly reviewed and approved. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards be supported by a system of internal control to maintain adequate documentation to support costs charged to the Federal award. Condition: During our testing of a sample of non-payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted one disbursement for which the District had no supporting documentation. Questioned Costs: $1,185.55 Cause: The District was unable to locate any documentation over this transaction. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls to ensure supporting documentation for all transactions is adequately maintained and properly reviewed and approved. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards be supported by a system of internal control to maintain adequate documentation to support costs charged to the Federal award. Condition: During our testing of a sample of non-payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted one disbursement for which the District had no supporting documentation. Questioned Costs: $1,185.55 Cause: The District was unable to locate any documentation over this transaction. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls to ensure supporting documentation for all transactions is adequately maintained and properly reviewed and approved. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards be supported by a system of internal control to maintain adequate documentation to support costs charged to the Federal award. Condition: During our testing of a sample of non-payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted one disbursement for which the District had no supporting documentation. Questioned Costs: $1,185.55 Cause: The District was unable to locate any documentation over this transaction. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls to ensure supporting documentation for all transactions is adequately maintained and properly reviewed and approved. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 7 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 7 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 7 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 7 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: S425U220045, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 8 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: S425U220045, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 8 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: S425U220045, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 8 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: S425U220045, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 8 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 26 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 26 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 26 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, be incorporated into the official records of the entity, and reasonable reflect the total activity for which the employee is compensated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted 26 disbursements without supporting time and effort documentation. Questioned Costs: None. Cause: The District did not have proper control processes in place to ensure time and effort documentation was being retained, reviewed and approved. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and time and effort documentation. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over payroll to ensure supporting documentation for time & effort is retained, reviewed and approved for all employees. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: 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 2 out of 2 covered transactions in fiscal year 2023. Context: Both of the covered transactions which were tested did not have documentation that the District performed the required verifications. Questioned Costs: None Cause: The District policy did not formalize the District’s suspension and debarment procedures. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over suspension and debarment to ensure that all covered transactions are properly verified to not be suspended or debarred such that a third party can clearly see and understand the detailed history of the procurement. Additionally, it is recommended the District formalize its procedures in a written policy. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: 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 2 out of 2 covered transactions in fiscal year 2023. Context: Both of the covered transactions which were tested did not have documentation that the District performed the required verifications. Questioned Costs: None Cause: The District policy did not formalize the District’s suspension and debarment procedures. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over suspension and debarment to ensure that all covered transactions are properly verified to not be suspended or debarred such that a third party can clearly see and understand the detailed history of the procurement. Additionally, it is recommended the District formalize its procedures in a written policy. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: 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 2 out of 2 covered transactions in fiscal year 2023. Context: Both of the covered transactions which were tested did not have documentation that the District performed the required verifications. Questioned Costs: None Cause: The District policy did not formalize the District’s suspension and debarment procedures. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over suspension and debarment to ensure that all covered transactions are properly verified to not be suspended or debarred such that a third party can clearly see and understand the detailed history of the procurement. Additionally, it is recommended the District formalize its procedures in a written policy. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: 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 2 out of 2 covered transactions in fiscal year 2023. Context: Both of the covered transactions which were tested did not have documentation that the District performed the required verifications. Questioned Costs: None Cause: The District policy did not formalize the District’s suspension and debarment procedures. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over suspension and debarment to ensure that all covered transactions are properly verified to not be suspended or debarred such that a third party can clearly see and understand the detailed history of the procurement. Additionally, it is recommended the District formalize its procedures in a written policy. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards be supported by a system of internal control to maintain adequate documentation to support costs charged to the Federal award. Condition: During our testing of a sample of non-payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted one disbursement for which the District had no supporting documentation. Questioned Costs: $1,185.55 Cause: The District was unable to locate any documentation over this transaction. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls to ensure supporting documentation for all transactions is adequately maintained and properly reviewed and approved. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards be supported by a system of internal control to maintain adequate documentation to support costs charged to the Federal award. Condition: During our testing of a sample of non-payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted one disbursement for which the District had no supporting documentation. Questioned Costs: $1,185.55 Cause: The District was unable to locate any documentation over this transaction. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls to ensure supporting documentation for all transactions is adequately maintained and properly reviewed and approved. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards be supported by a system of internal control to maintain adequate documentation to support costs charged to the Federal award. Condition: During our testing of a sample of non-payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted one disbursement for which the District had no supporting documentation. Questioned Costs: $1,185.55 Cause: The District was unable to locate any documentation over this transaction. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls to ensure supporting documentation for all transactions is adequately maintained and properly reviewed and approved. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The Uniform Guidance requires charges to Federal awards be supported by a system of internal control to maintain adequate documentation to support costs charged to the Federal award. Condition: During our testing of a sample of non-payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Context: Of a sample of 40 payroll disbursements charged to the grant we noted one disbursement for which the District had no supporting documentation. Questioned Costs: $1,185.55 Cause: The District was unable to locate any documentation over this transaction. Effect: The District was not in compliance with the Uniform Guidance requirements around cost principles and documentation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls to ensure supporting documentation for all transactions is adequately maintained and properly reviewed and approved. Views of Responsible Officials: There is no disagreement with the audit finding.