Audit 331563

FY End
2024-06-30
Total Expended
$8.92M
Findings
12
Programs
14
Year: 2024 Accepted: 2024-12-09

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
513650 2024-001 Significant Deficiency - I
513651 2024-001 Significant Deficiency - I
513652 2024-001 Significant Deficiency - I
513653 2024-002 Significant Deficiency - I
513654 2024-002 Significant Deficiency - I
513655 2024-002 Significant Deficiency - I
1090092 2024-001 Significant Deficiency - I
1090093 2024-001 Significant Deficiency - I
1090094 2024-001 Significant Deficiency - I
1090095 2024-002 Significant Deficiency - I
1090096 2024-002 Significant Deficiency - I
1090097 2024-002 Significant Deficiency - I

Contacts

Name Title Type
DV15J5C3BEJ9 Joseph Primus Auditee
7632413437 William Lauer Auditor
No contacts on file

Notes to SEFA

Title: Additional Note #1 Accounting Policies: The Schedule of Expenditures of Federal Awards is prepared on the accrual basis of accounting. The information in this schedule is presented in accordance with the OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Therefore, some amounts presented in this schedule may differ from the amounts presented in, or used in the preparation of, the District’s basic financial statements. All pass-through entities listed above use the same federal Assistance Listing Number (ALN) as the federal grantors to identify these grants. De Minimis Rate Used: N Rate Explanation: The District did not elect to use the 10 percent de minimis indirect cost rate. The District had $719,154 of noncash assistance included in the National School Lunch Program, federal ALN 10.555.

Finding Details

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 requires Independent School District No. 728 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to child nutrition cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to assure it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Our testing did not indicate any instances of noncompliance with this requirement. Context – The District has properly designed internal controls in place over suspension and debarment requirements applicable to special education cluster federal programs. However, for three of three contracts tested, the District did not retain adequate documentation that these procedures had been performed. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – The District did not retain adequate documentation that it had verified the vendors with which the District contracted for goods or services exceeding $25,000 during the year within its special education cluster federal programs were not suspended or debarred. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to suspension and debarment applicable to special education cluster federal programs. Internal controls over compliance for this area should include adequate documentation of verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District will review and update its policies and procedures relating to suspension and debarment applicable to special education cluster federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 requires Independent School District No. 728 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to child nutrition cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to assure it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Our testing did not indicate any instances of noncompliance with this requirement. Context – The District has properly designed internal controls in place over suspension and debarment requirements applicable to special education cluster federal programs. However, for three of three contracts tested, the District did not retain adequate documentation that these procedures had been performed. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – The District did not retain adequate documentation that it had verified the vendors with which the District contracted for goods or services exceeding $25,000 during the year within its special education cluster federal programs were not suspended or debarred. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to suspension and debarment applicable to special education cluster federal programs. Internal controls over compliance for this area should include adequate documentation of verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District will review and update its policies and procedures relating to suspension and debarment applicable to special education cluster federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 requires Independent School District No. 728 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to child nutrition cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to assure it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Our testing did not indicate any instances of noncompliance with this requirement. Context – The District has properly designed internal controls in place over suspension and debarment requirements applicable to special education cluster federal programs. However, for three of three contracts tested, the District did not retain adequate documentation that these procedures had been performed. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – The District did not retain adequate documentation that it had verified the vendors with which the District contracted for goods or services exceeding $25,000 during the year within its special education cluster federal programs were not suspended or debarred. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to suspension and debarment applicable to special education cluster federal programs. Internal controls over compliance for this area should include adequate documentation of verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District will review and update its policies and procedures relating to suspension and debarment applicable to special education cluster federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORETABLE INSTANCES OF NONCOMPLIANCE– U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-002 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Criteria – 2CFR § 200.320 requires the District to establish and maintain effective internal control over compliance with procurement requirements applicable to expenditures within its special education cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in reportable instances of noncompliance. Questioned Costs – $92,850. Context – For two of six vendors tested, the District did not obtain two or more quotations for contracts awarded in excess of its stated micro-purchase threshold of $10,000 within its special education cluster federal programs, as required by the Uniform Guidance. All contracts required to be awarded based on multiple quotations within the District’s special education cluster federal programs were tested. Repeat Finding – This is a current year finding. Cause – The District’s internal control procedures over procurement requirements applicable to its special education cluster federal programs were not being consistently followed. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or not obtaining competitively prices goods or services, which could be viewed as a violation of the award agreement. Recommendation – We recommend the District review its internal control procedures for its special education cluster federal programs to ensure that controls in place over compliance with federal procurement requirements are being consistently applied, including awarding contracts based on multiple quotations for the purchase of goods or services in excess of the District’s micro-purchase threshold of $10,000, as required by the Uniform Guidance. View of Responsible Official and Planned Corrective Actions – There is no disagreement with the audit finding. District management will review its procedures relating to procurement for its federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORETABLE INSTANCES OF NONCOMPLIANCE– U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-002 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Criteria – 2CFR § 200.320 requires the District to establish and maintain effective internal control over compliance with procurement requirements applicable to expenditures within its special education cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in reportable instances of noncompliance. Questioned Costs – $92,850. Context – For two of six vendors tested, the District did not obtain two or more quotations for contracts awarded in excess of its stated micro-purchase threshold of $10,000 within its special education cluster federal programs, as required by the Uniform Guidance. All contracts required to be awarded based on multiple quotations within the District’s special education cluster federal programs were tested. Repeat Finding – This is a current year finding. Cause – The District’s internal control procedures over procurement requirements applicable to its special education cluster federal programs were not being consistently followed. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or not obtaining competitively prices goods or services, which could be viewed as a violation of the award agreement. Recommendation – We recommend the District review its internal control procedures for its special education cluster federal programs to ensure that controls in place over compliance with federal procurement requirements are being consistently applied, including awarding contracts based on multiple quotations for the purchase of goods or services in excess of the District’s micro-purchase threshold of $10,000, as required by the Uniform Guidance. View of Responsible Official and Planned Corrective Actions – There is no disagreement with the audit finding. District management will review its procedures relating to procurement for its federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORETABLE INSTANCES OF NONCOMPLIANCE– U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-002 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Criteria – 2CFR § 200.320 requires the District to establish and maintain effective internal control over compliance with procurement requirements applicable to expenditures within its special education cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in reportable instances of noncompliance. Questioned Costs – $92,850. Context – For two of six vendors tested, the District did not obtain two or more quotations for contracts awarded in excess of its stated micro-purchase threshold of $10,000 within its special education cluster federal programs, as required by the Uniform Guidance. All contracts required to be awarded based on multiple quotations within the District’s special education cluster federal programs were tested. Repeat Finding – This is a current year finding. Cause – The District’s internal control procedures over procurement requirements applicable to its special education cluster federal programs were not being consistently followed. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or not obtaining competitively prices goods or services, which could be viewed as a violation of the award agreement. Recommendation – We recommend the District review its internal control procedures for its special education cluster federal programs to ensure that controls in place over compliance with federal procurement requirements are being consistently applied, including awarding contracts based on multiple quotations for the purchase of goods or services in excess of the District’s micro-purchase threshold of $10,000, as required by the Uniform Guidance. View of Responsible Official and Planned Corrective Actions – There is no disagreement with the audit finding. District management will review its procedures relating to procurement for its federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 requires Independent School District No. 728 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to child nutrition cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to assure it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Our testing did not indicate any instances of noncompliance with this requirement. Context – The District has properly designed internal controls in place over suspension and debarment requirements applicable to special education cluster federal programs. However, for three of three contracts tested, the District did not retain adequate documentation that these procedures had been performed. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – The District did not retain adequate documentation that it had verified the vendors with which the District contracted for goods or services exceeding $25,000 during the year within its special education cluster federal programs were not suspended or debarred. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to suspension and debarment applicable to special education cluster federal programs. Internal controls over compliance for this area should include adequate documentation of verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District will review and update its policies and procedures relating to suspension and debarment applicable to special education cluster federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 requires Independent School District No. 728 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to child nutrition cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to assure it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Our testing did not indicate any instances of noncompliance with this requirement. Context – The District has properly designed internal controls in place over suspension and debarment requirements applicable to special education cluster federal programs. However, for three of three contracts tested, the District did not retain adequate documentation that these procedures had been performed. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – The District did not retain adequate documentation that it had verified the vendors with which the District contracted for goods or services exceeding $25,000 during the year within its special education cluster federal programs were not suspended or debarred. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to suspension and debarment applicable to special education cluster federal programs. Internal controls over compliance for this area should include adequate documentation of verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District will review and update its policies and procedures relating to suspension and debarment applicable to special education cluster federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 requires Independent School District No. 728 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to child nutrition cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to assure it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Our testing did not indicate any instances of noncompliance with this requirement. Context – The District has properly designed internal controls in place over suspension and debarment requirements applicable to special education cluster federal programs. However, for three of three contracts tested, the District did not retain adequate documentation that these procedures had been performed. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – The District did not retain adequate documentation that it had verified the vendors with which the District contracted for goods or services exceeding $25,000 during the year within its special education cluster federal programs were not suspended or debarred. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to suspension and debarment applicable to special education cluster federal programs. Internal controls over compliance for this area should include adequate documentation of verification that any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District will review and update its policies and procedures relating to suspension and debarment applicable to special education cluster federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORETABLE INSTANCES OF NONCOMPLIANCE– U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-002 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Criteria – 2CFR § 200.320 requires the District to establish and maintain effective internal control over compliance with procurement requirements applicable to expenditures within its special education cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in reportable instances of noncompliance. Questioned Costs – $92,850. Context – For two of six vendors tested, the District did not obtain two or more quotations for contracts awarded in excess of its stated micro-purchase threshold of $10,000 within its special education cluster federal programs, as required by the Uniform Guidance. All contracts required to be awarded based on multiple quotations within the District’s special education cluster federal programs were tested. Repeat Finding – This is a current year finding. Cause – The District’s internal control procedures over procurement requirements applicable to its special education cluster federal programs were not being consistently followed. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or not obtaining competitively prices goods or services, which could be viewed as a violation of the award agreement. Recommendation – We recommend the District review its internal control procedures for its special education cluster federal programs to ensure that controls in place over compliance with federal procurement requirements are being consistently applied, including awarding contracts based on multiple quotations for the purchase of goods or services in excess of the District’s micro-purchase threshold of $10,000, as required by the Uniform Guidance. View of Responsible Official and Planned Corrective Actions – There is no disagreement with the audit finding. District management will review its procedures relating to procurement for its federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORETABLE INSTANCES OF NONCOMPLIANCE– U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-002 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Criteria – 2CFR § 200.320 requires the District to establish and maintain effective internal control over compliance with procurement requirements applicable to expenditures within its special education cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in reportable instances of noncompliance. Questioned Costs – $92,850. Context – For two of six vendors tested, the District did not obtain two or more quotations for contracts awarded in excess of its stated micro-purchase threshold of $10,000 within its special education cluster federal programs, as required by the Uniform Guidance. All contracts required to be awarded based on multiple quotations within the District’s special education cluster federal programs were tested. Repeat Finding – This is a current year finding. Cause – The District’s internal control procedures over procurement requirements applicable to its special education cluster federal programs were not being consistently followed. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or not obtaining competitively prices goods or services, which could be viewed as a violation of the award agreement. Recommendation – We recommend the District review its internal control procedures for its special education cluster federal programs to ensure that controls in place over compliance with federal procurement requirements are being consistently applied, including awarding contracts based on multiple quotations for the purchase of goods or services in excess of the District’s micro-purchase threshold of $10,000, as required by the Uniform Guidance. View of Responsible Official and Planned Corrective Actions – There is no disagreement with the audit finding. District management will review its procedures relating to procurement for its federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. The District has separately issued a Corrective Action Plan related to this finding.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORETABLE INSTANCES OF NONCOMPLIANCE– U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-002 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Criteria – 2CFR § 200.320 requires the District to establish and maintain effective internal control over compliance with procurement requirements applicable to expenditures within its special education cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in reportable instances of noncompliance. Questioned Costs – $92,850. Context – For two of six vendors tested, the District did not obtain two or more quotations for contracts awarded in excess of its stated micro-purchase threshold of $10,000 within its special education cluster federal programs, as required by the Uniform Guidance. All contracts required to be awarded based on multiple quotations within the District’s special education cluster federal programs were tested. Repeat Finding – This is a current year finding. Cause – The District’s internal control procedures over procurement requirements applicable to its special education cluster federal programs were not being consistently followed. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or not obtaining competitively prices goods or services, which could be viewed as a violation of the award agreement. Recommendation – We recommend the District review its internal control procedures for its special education cluster federal programs to ensure that controls in place over compliance with federal procurement requirements are being consistently applied, including awarding contracts based on multiple quotations for the purchase of goods or services in excess of the District’s micro-purchase threshold of $10,000, as required by the Uniform Guidance. View of Responsible Official and Planned Corrective Actions – There is no disagreement with the audit finding. District management will review its procedures relating to procurement for its federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. The District has separately issued a Corrective Action Plan related to this finding.