Audit 350425

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Costs charged to the program should be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Condition The District incurred the following expenditures to the program with the following items noted: Check 236621 Dated 12/20/2023 for $49,600 The expenditure amount for Health Eating and Living workshop that did not appear to be reasonable for the performance of the federal award. No documentation was available to account for the supplies and other costs included in the check amount. Check 236241 Dated 11/22/2023 for $49,394 The expenditure amount for a Video Editing class that did not appear to be reasonable for the performance of the federal award. In addition, the amounts paid to the vendor for computer purchases exceeded market value. Check 238235 Dated 5/6/2024 for $676 The expenditure was for staff travel. In accordance with District policies, a Staff Travel Request Form is required. This form was not maintained. Context In a total population exceeding 250 expenditures, forty (40) transactions were tested. Three (3) of these transactions were found with exceptions. Cause The District did not properly obtain all invoice documentation and proper review to ensure expenditures were necessary and reasonable for the performance of the federal award. Effect The District may have incurred costs deemed excessive for the grant. Questioned Costs $99,670 Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Costs charged to the program should be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Condition The District incurred the following expenditures to the program with the following items noted: Check 236621 Dated 12/20/2023 for $49,600 The expenditure amount for Health Eating and Living workshop that did not appear to be reasonable for the performance of the federal award. No documentation was available to account for the supplies and other costs included in the check amount. Check 236241 Dated 11/22/2023 for $49,394 The expenditure amount for a Video Editing class that did not appear to be reasonable for the performance of the federal award. In addition, the amounts paid to the vendor for computer purchases exceeded market value. Check 238235 Dated 5/6/2024 for $676 The expenditure was for staff travel. In accordance with District policies, a Staff Travel Request Form is required. This form was not maintained. Context In a total population exceeding 250 expenditures, forty (40) transactions were tested. Three (3) of these transactions were found with exceptions. Cause The District did not properly obtain all invoice documentation and proper review to ensure expenditures were necessary and reasonable for the performance of the federal award. Effect The District may have incurred costs deemed excessive for the grant. Questioned Costs $99,670 Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Costs charged to the program should be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Condition The District incurred the following expenditures to the program with the following items noted: Check 236621 Dated 12/20/2023 for $49,600 The expenditure amount for Health Eating and Living workshop that did not appear to be reasonable for the performance of the federal award. No documentation was available to account for the supplies and other costs included in the check amount. Check 236241 Dated 11/22/2023 for $49,394 The expenditure amount for a Video Editing class that did not appear to be reasonable for the performance of the federal award. In addition, the amounts paid to the vendor for computer purchases exceeded market value. Check 238235 Dated 5/6/2024 for $676 The expenditure was for staff travel. In accordance with District policies, a Staff Travel Request Form is required. This form was not maintained. Context In a total population exceeding 250 expenditures, forty (40) transactions were tested. Three (3) of these transactions were found with exceptions. Cause The District did not properly obtain all invoice documentation and proper review to ensure expenditures were necessary and reasonable for the performance of the federal award. Effect The District may have incurred costs deemed excessive for the grant. Questioned Costs $99,670 Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. Context Per discussion with the District staff and review of program expenditures, there were 19 capital asset acquisitions during the year, we tested all of them for prior state approval. One purchase was approved by the state after the purchase was made. Seven purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2023-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. Context Per discussion with the District staff and review of program expenditures, there were 19 capital asset acquisitions during the year, we tested all of them for prior state approval. One purchase was approved by the state after the purchase was made. Seven purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2023-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. Context Per discussion with the District staff and review of program expenditures, there were 19 capital asset acquisitions during the year, we tested all of them for prior state approval. One purchase was approved by the state after the purchase was made. Seven purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2023-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.

Assistance Listing Number 84.181 Special Education – Grants for Infants and Families Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Maintenance of Effort Criteria The total amount of state and local funds budgeted for expenditure in the current fiscal year for early intervention services for children eligible under Part C and their families must be at least equal to the total amount of state and local funds actually expended for early intervention services for these children and their families in the most recent preceding fiscal year for which the information is available. Condition District does not currently monitor this compliance requirement. Context Not Applicable Cause District does not currently have appropriately designed internal controls in place to ensure all compliance requirements are being monitored Effect Lack of internal controls to monitor the compliance requirements could cause the District to fall out of compliance. Questioned Costs Not Applicable Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all compliance requirements are both being monitored and District is remaining in compliance. Management’s Response See corrective action plan.

Assistance Listing Number 84.181 Special Education – Grants for Infants and Families Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Maintenance of Effort Criteria The total amount of state and local funds budgeted for expenditure in the current fiscal year for early intervention services for children eligible under Part C and their families must be at least equal to the total amount of state and local funds actually expended for early intervention services for these children and their families in the most recent preceding fiscal year for which the information is available. Condition District does not currently monitor this compliance requirement. Context Not Applicable Cause District does not currently have appropriately designed internal controls in place to ensure all compliance requirements are being monitored Effect Lack of internal controls to monitor the compliance requirements could cause the District to fall out of compliance. Questioned Costs Not Applicable Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all compliance requirements are both being monitored and District is remaining in compliance. Management’s Response See corrective action plan.

Assistance Listing Number 84.181 Special Education Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Procurement 2 CFR Part 200.317 through 200.327 Criteria Procurement Standards require for the District to maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in 2 CFR Part 200.317 through 200.327. Condition The District performed a procurement activity that did not follow District policies as well as standards found in 2 CFR Part 200.317 through 200.327. The District failed to obtain quotes or bids for a purchase exceeding $10,000. Context Per discussion with the District staff and review of program expenditures, there were 4 expenditures incurred in which quotes or bids should have been obtained. All four transactions were tested and it was noted that 1 transaction did not have the necessary quotes or bids. Cause District’s internal controls in place failed to ensure all procurement policies are followed. Effect District is not in compliance with their internal procurement policies and procurement standards. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all internal policies and compliance requirements are both being monitored and the District is remaining in compliance. Management’s Response See corrective action plan.

Assistance Listing Number 84.181 Special Education Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Procurement 2 CFR Part 200.317 through 200.327 Criteria Procurement Standards require for the District to maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in 2 CFR Part 200.317 through 200.327. Condition The District performed a procurement activity that did not follow District policies as well as standards found in 2 CFR Part 200.317 through 200.327. The District failed to obtain quotes or bids for a purchase exceeding $10,000. Context Per discussion with the District staff and review of program expenditures, there were 4 expenditures incurred in which quotes or bids should have been obtained. All four transactions were tested and it was noted that 1 transaction did not have the necessary quotes or bids. Cause District’s internal controls in place failed to ensure all procurement policies are followed. Effect District is not in compliance with their internal procurement policies and procurement standards. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all internal policies and compliance requirements are both being monitored and the District is remaining in compliance. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Costs charged to the program should be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Condition The District incurred the following expenditures to the program with the following items noted: Check 236621 Dated 12/20/2023 for $49,600 The expenditure amount for Health Eating and Living workshop that did not appear to be reasonable for the performance of the federal award. No documentation was available to account for the supplies and other costs included in the check amount. Check 236241 Dated 11/22/2023 for $49,394 The expenditure amount for a Video Editing class that did not appear to be reasonable for the performance of the federal award. In addition, the amounts paid to the vendor for computer purchases exceeded market value. Check 238235 Dated 5/6/2024 for $676 The expenditure was for staff travel. In accordance with District policies, a Staff Travel Request Form is required. This form was not maintained. Context In a total population exceeding 250 expenditures, forty (40) transactions were tested. Three (3) of these transactions were found with exceptions. Cause The District did not properly obtain all invoice documentation and proper review to ensure expenditures were necessary and reasonable for the performance of the federal award. Effect The District may have incurred costs deemed excessive for the grant. Questioned Costs $99,670 Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Costs charged to the program should be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Condition The District incurred the following expenditures to the program with the following items noted: Check 236621 Dated 12/20/2023 for $49,600 The expenditure amount for Health Eating and Living workshop that did not appear to be reasonable for the performance of the federal award. No documentation was available to account for the supplies and other costs included in the check amount. Check 236241 Dated 11/22/2023 for $49,394 The expenditure amount for a Video Editing class that did not appear to be reasonable for the performance of the federal award. In addition, the amounts paid to the vendor for computer purchases exceeded market value. Check 238235 Dated 5/6/2024 for $676 The expenditure was for staff travel. In accordance with District policies, a Staff Travel Request Form is required. This form was not maintained. Context In a total population exceeding 250 expenditures, forty (40) transactions were tested. Three (3) of these transactions were found with exceptions. Cause The District did not properly obtain all invoice documentation and proper review to ensure expenditures were necessary and reasonable for the performance of the federal award. Effect The District may have incurred costs deemed excessive for the grant. Questioned Costs $99,670 Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Costs charged to the program should be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Condition The District incurred the following expenditures to the program with the following items noted: Check 236621 Dated 12/20/2023 for $49,600 The expenditure amount for Health Eating and Living workshop that did not appear to be reasonable for the performance of the federal award. No documentation was available to account for the supplies and other costs included in the check amount. Check 236241 Dated 11/22/2023 for $49,394 The expenditure amount for a Video Editing class that did not appear to be reasonable for the performance of the federal award. In addition, the amounts paid to the vendor for computer purchases exceeded market value. Check 238235 Dated 5/6/2024 for $676 The expenditure was for staff travel. In accordance with District policies, a Staff Travel Request Form is required. This form was not maintained. Context In a total population exceeding 250 expenditures, forty (40) transactions were tested. Three (3) of these transactions were found with exceptions. Cause The District did not properly obtain all invoice documentation and proper review to ensure expenditures were necessary and reasonable for the performance of the federal award. Effect The District may have incurred costs deemed excessive for the grant. Questioned Costs $99,670 Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. Context Per discussion with the District staff and review of program expenditures, there were 19 capital asset acquisitions during the year, we tested all of them for prior state approval. One purchase was approved by the state after the purchase was made. Seven purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2023-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. Context Per discussion with the District staff and review of program expenditures, there were 19 capital asset acquisitions during the year, we tested all of them for prior state approval. One purchase was approved by the state after the purchase was made. Seven purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2023-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.

Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. Context Per discussion with the District staff and review of program expenditures, there were 19 capital asset acquisitions during the year, we tested all of them for prior state approval. One purchase was approved by the state after the purchase was made. Seven purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2023-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.

Assistance Listing Number 84.181 Special Education – Grants for Infants and Families Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Maintenance of Effort Criteria The total amount of state and local funds budgeted for expenditure in the current fiscal year for early intervention services for children eligible under Part C and their families must be at least equal to the total amount of state and local funds actually expended for early intervention services for these children and their families in the most recent preceding fiscal year for which the information is available. Condition District does not currently monitor this compliance requirement. Context Not Applicable Cause District does not currently have appropriately designed internal controls in place to ensure all compliance requirements are being monitored Effect Lack of internal controls to monitor the compliance requirements could cause the District to fall out of compliance. Questioned Costs Not Applicable Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all compliance requirements are both being monitored and District is remaining in compliance. Management’s Response See corrective action plan.

Assistance Listing Number 84.181 Special Education – Grants for Infants and Families Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Maintenance of Effort Criteria The total amount of state and local funds budgeted for expenditure in the current fiscal year for early intervention services for children eligible under Part C and their families must be at least equal to the total amount of state and local funds actually expended for early intervention services for these children and their families in the most recent preceding fiscal year for which the information is available. Condition District does not currently monitor this compliance requirement. Context Not Applicable Cause District does not currently have appropriately designed internal controls in place to ensure all compliance requirements are being monitored Effect Lack of internal controls to monitor the compliance requirements could cause the District to fall out of compliance. Questioned Costs Not Applicable Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all compliance requirements are both being monitored and District is remaining in compliance. Management’s Response See corrective action plan.

Assistance Listing Number 84.181 Special Education Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Procurement 2 CFR Part 200.317 through 200.327 Criteria Procurement Standards require for the District to maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in 2 CFR Part 200.317 through 200.327. Condition The District performed a procurement activity that did not follow District policies as well as standards found in 2 CFR Part 200.317 through 200.327. The District failed to obtain quotes or bids for a purchase exceeding $10,000. Context Per discussion with the District staff and review of program expenditures, there were 4 expenditures incurred in which quotes or bids should have been obtained. All four transactions were tested and it was noted that 1 transaction did not have the necessary quotes or bids. Cause District’s internal controls in place failed to ensure all procurement policies are followed. Effect District is not in compliance with their internal procurement policies and procurement standards. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all internal policies and compliance requirements are both being monitored and the District is remaining in compliance. Management’s Response See corrective action plan.

Assistance Listing Number 84.181 Special Education Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Procurement 2 CFR Part 200.317 through 200.327 Criteria Procurement Standards require for the District to maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in 2 CFR Part 200.317 through 200.327. Condition The District performed a procurement activity that did not follow District policies as well as standards found in 2 CFR Part 200.317 through 200.327. The District failed to obtain quotes or bids for a purchase exceeding $10,000. Context Per discussion with the District staff and review of program expenditures, there were 4 expenditures incurred in which quotes or bids should have been obtained. All four transactions were tested and it was noted that 1 transaction did not have the necessary quotes or bids. Cause District’s internal controls in place failed to ensure all procurement policies are followed. Effect District is not in compliance with their internal procurement policies and procurement standards. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all internal policies and compliance requirements are both being monitored and the District is remaining in compliance. Management’s Response See corrective action plan.