Audit 35122

FY End
2022-06-30
Total Expended
$894,751
Findings
16
Programs
12
Organization: Cologne Academy (MN)
Year: 2022 Accepted: 2023-03-30

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
38565 2022-001 Material Weakness - I
38566 2022-002 Material Weakness - I
38567 2022-001 Material Weakness - I
38568 2022-002 Material Weakness - I
38569 2022-001 Material Weakness - I
38570 2022-002 Material Weakness - I
38571 2022-001 Material Weakness - I
38572 2022-002 Material Weakness - I
615007 2022-001 Material Weakness - I
615008 2022-002 Material Weakness - I
615009 2022-001 Material Weakness - I
615010 2022-002 Material Weakness - I
615011 2022-001 Material Weakness - I
615012 2022-002 Material Weakness - I
615013 2022-001 Material Weakness - I
615014 2022-002 Material Weakness - I

Contacts

Name Title Type
MDKZN6JKSBA8 Traci Laferriere Auditee
9524662276 Michelle Hoffman Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards. Under these principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Cologne Academy has not elected to use the 10 percent de minimis indirect cost rate asallowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of the Cologne Academy (the School) under programs of the federal government for the year ended June 30, 2022. The information in this Schedule is presented in accordance with the requirements of 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the School, it is not intended to and does not present the financial position, changes in net position, or cash flows of the School.
Title: U.S. DEPARTMENT OF AGRICULTURE Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards. Under these principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Cologne Academy has not elected to use the 10 percent de minimis indirect cost rate asallowed under the Uniform Guidance. The amount reported for the National School Lunch Program Noncash Assistance(Commodities) represents nonmonetary assistance and is reported in the Schedule at thefair market value of the commodities received. The amounts reported for the NationalSchool Lunch Program Cash Assistance and COVID-19 Supply Chain Assistance, and theSchool Breakfast Program represent cash receipts from federal reimbursements.

Finding Details

2022 ? 001 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: ?200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and the School should have controls in place to ensure compliance with procurement requirements of the Child Nutrition Cluster program. Additionally, ?200.318 states that the School must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: There was a lack of documentation and controls noted for two procurements, out of eight tested. For one of the procurements, the original signed quote was obtained, but no other documentation could be located. For the other contract, it started off as a small, verbal agreement several years ago and the related cleaning costs increased as the school grew over the years, with the only procurement documentation being signed annual agreements. Questioned costs: $56,110 for ALN 10.553 and 10.555 Context: Two of seven procurements tested were not supported by proper documentation detailing the complete history of the transaction or formal documentation of the controls in place over compliance to ensure the formal documentation of the reasoning for the procurement decision. Cause: The vendors had been used for several years and the amount of the related expenditures paid to the vendors increased with the School?s size and needs. Therefore, any formal documentation of the original procurement decision to use the vendor was no longer on file with the School. Effect: Lack of proper documentation of procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Uniform Guidance requires the School to have a written procurement policy per ?200.319. This policy should detail the method of procurement the School follows, including the School's micro-purchase threshold. Condition: The School has a written procurement policy, but it did not detail a micro-purchase threshold. Questioned costs: None Context: The School has a written procurement policy, but it did not detail its micro-purchase threshold. But it did note that it required bids for any contract over $25,000. Cause: The School was not aware that this requirement was missing from its current policy. Effect: The School is not in compliance with this policy requirement. This could result in the related procedures for procurements in amounts below their policy's requirement to obtain bids for contracts over $25,000 not being clear to School staff, which could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend that the School review its procurement policy for compliance with the Uniform Guidance and add a micro-purchase threshold to its procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 001 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: ?200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and the School should have controls in place to ensure compliance with procurement requirements of the Child Nutrition Cluster program. Additionally, ?200.318 states that the School must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: There was a lack of documentation and controls noted for two procurements, out of eight tested. For one of the procurements, the original signed quote was obtained, but no other documentation could be located. For the other contract, it started off as a small, verbal agreement several years ago and the related cleaning costs increased as the school grew over the years, with the only procurement documentation being signed annual agreements. Questioned costs: $56,110 for ALN 10.553 and 10.555 Context: Two of seven procurements tested were not supported by proper documentation detailing the complete history of the transaction or formal documentation of the controls in place over compliance to ensure the formal documentation of the reasoning for the procurement decision. Cause: The vendors had been used for several years and the amount of the related expenditures paid to the vendors increased with the School?s size and needs. Therefore, any formal documentation of the original procurement decision to use the vendor was no longer on file with the School. Effect: Lack of proper documentation of procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Uniform Guidance requires the School to have a written procurement policy per ?200.319. This policy should detail the method of procurement the School follows, including the School's micro-purchase threshold. Condition: The School has a written procurement policy, but it did not detail a micro-purchase threshold. Questioned costs: None Context: The School has a written procurement policy, but it did not detail its micro-purchase threshold. But it did note that it required bids for any contract over $25,000. Cause: The School was not aware that this requirement was missing from its current policy. Effect: The School is not in compliance with this policy requirement. This could result in the related procedures for procurements in amounts below their policy's requirement to obtain bids for contracts over $25,000 not being clear to School staff, which could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend that the School review its procurement policy for compliance with the Uniform Guidance and add a micro-purchase threshold to its procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 001 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: ?200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and the School should have controls in place to ensure compliance with procurement requirements of the Child Nutrition Cluster program. Additionally, ?200.318 states that the School must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: There was a lack of documentation and controls noted for two procurements, out of eight tested. For one of the procurements, the original signed quote was obtained, but no other documentation could be located. For the other contract, it started off as a small, verbal agreement several years ago and the related cleaning costs increased as the school grew over the years, with the only procurement documentation being signed annual agreements. Questioned costs: $56,110 for ALN 10.553 and 10.555 Context: Two of seven procurements tested were not supported by proper documentation detailing the complete history of the transaction or formal documentation of the controls in place over compliance to ensure the formal documentation of the reasoning for the procurement decision. Cause: The vendors had been used for several years and the amount of the related expenditures paid to the vendors increased with the School?s size and needs. Therefore, any formal documentation of the original procurement decision to use the vendor was no longer on file with the School. Effect: Lack of proper documentation of procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Uniform Guidance requires the School to have a written procurement policy per ?200.319. This policy should detail the method of procurement the School follows, including the School's micro-purchase threshold. Condition: The School has a written procurement policy, but it did not detail a micro-purchase threshold. Questioned costs: None Context: The School has a written procurement policy, but it did not detail its micro-purchase threshold. But it did note that it required bids for any contract over $25,000. Cause: The School was not aware that this requirement was missing from its current policy. Effect: The School is not in compliance with this policy requirement. This could result in the related procedures for procurements in amounts below their policy's requirement to obtain bids for contracts over $25,000 not being clear to School staff, which could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend that the School review its procurement policy for compliance with the Uniform Guidance and add a micro-purchase threshold to its procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 001 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: ?200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and the School should have controls in place to ensure compliance with procurement requirements of the Child Nutrition Cluster program. Additionally, ?200.318 states that the School must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: There was a lack of documentation and controls noted for two procurements, out of eight tested. For one of the procurements, the original signed quote was obtained, but no other documentation could be located. For the other contract, it started off as a small, verbal agreement several years ago and the related cleaning costs increased as the school grew over the years, with the only procurement documentation being signed annual agreements. Questioned costs: $56,110 for ALN 10.553 and 10.555 Context: Two of seven procurements tested were not supported by proper documentation detailing the complete history of the transaction or formal documentation of the controls in place over compliance to ensure the formal documentation of the reasoning for the procurement decision. Cause: The vendors had been used for several years and the amount of the related expenditures paid to the vendors increased with the School?s size and needs. Therefore, any formal documentation of the original procurement decision to use the vendor was no longer on file with the School. Effect: Lack of proper documentation of procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Uniform Guidance requires the School to have a written procurement policy per ?200.319. This policy should detail the method of procurement the School follows, including the School's micro-purchase threshold. Condition: The School has a written procurement policy, but it did not detail a micro-purchase threshold. Questioned costs: None Context: The School has a written procurement policy, but it did not detail its micro-purchase threshold. But it did note that it required bids for any contract over $25,000. Cause: The School was not aware that this requirement was missing from its current policy. Effect: The School is not in compliance with this policy requirement. This could result in the related procedures for procurements in amounts below their policy's requirement to obtain bids for contracts over $25,000 not being clear to School staff, which could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend that the School review its procurement policy for compliance with the Uniform Guidance and add a micro-purchase threshold to its procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 001 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: ?200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and the School should have controls in place to ensure compliance with procurement requirements of the Child Nutrition Cluster program. Additionally, ?200.318 states that the School must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: There was a lack of documentation and controls noted for two procurements, out of eight tested. For one of the procurements, the original signed quote was obtained, but no other documentation could be located. For the other contract, it started off as a small, verbal agreement several years ago and the related cleaning costs increased as the school grew over the years, with the only procurement documentation being signed annual agreements. Questioned costs: $56,110 for ALN 10.553 and 10.555 Context: Two of seven procurements tested were not supported by proper documentation detailing the complete history of the transaction or formal documentation of the controls in place over compliance to ensure the formal documentation of the reasoning for the procurement decision. Cause: The vendors had been used for several years and the amount of the related expenditures paid to the vendors increased with the School?s size and needs. Therefore, any formal documentation of the original procurement decision to use the vendor was no longer on file with the School. Effect: Lack of proper documentation of procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Uniform Guidance requires the School to have a written procurement policy per ?200.319. This policy should detail the method of procurement the School follows, including the School's micro-purchase threshold. Condition: The School has a written procurement policy, but it did not detail a micro-purchase threshold. Questioned costs: None Context: The School has a written procurement policy, but it did not detail its micro-purchase threshold. But it did note that it required bids for any contract over $25,000. Cause: The School was not aware that this requirement was missing from its current policy. Effect: The School is not in compliance with this policy requirement. This could result in the related procedures for procurements in amounts below their policy's requirement to obtain bids for contracts over $25,000 not being clear to School staff, which could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend that the School review its procurement policy for compliance with the Uniform Guidance and add a micro-purchase threshold to its procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 001 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: ?200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and the School should have controls in place to ensure compliance with procurement requirements of the Child Nutrition Cluster program. Additionally, ?200.318 states that the School must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: There was a lack of documentation and controls noted for two procurements, out of eight tested. For one of the procurements, the original signed quote was obtained, but no other documentation could be located. For the other contract, it started off as a small, verbal agreement several years ago and the related cleaning costs increased as the school grew over the years, with the only procurement documentation being signed annual agreements. Questioned costs: $56,110 for ALN 10.553 and 10.555 Context: Two of seven procurements tested were not supported by proper documentation detailing the complete history of the transaction or formal documentation of the controls in place over compliance to ensure the formal documentation of the reasoning for the procurement decision. Cause: The vendors had been used for several years and the amount of the related expenditures paid to the vendors increased with the School?s size and needs. Therefore, any formal documentation of the original procurement decision to use the vendor was no longer on file with the School. Effect: Lack of proper documentation of procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Uniform Guidance requires the School to have a written procurement policy per ?200.319. This policy should detail the method of procurement the School follows, including the School's micro-purchase threshold. Condition: The School has a written procurement policy, but it did not detail a micro-purchase threshold. Questioned costs: None Context: The School has a written procurement policy, but it did not detail its micro-purchase threshold. But it did note that it required bids for any contract over $25,000. Cause: The School was not aware that this requirement was missing from its current policy. Effect: The School is not in compliance with this policy requirement. This could result in the related procedures for procurements in amounts below their policy's requirement to obtain bids for contracts over $25,000 not being clear to School staff, which could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend that the School review its procurement policy for compliance with the Uniform Guidance and add a micro-purchase threshold to its procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 001 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: ?200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and the School should have controls in place to ensure compliance with procurement requirements of the Child Nutrition Cluster program. Additionally, ?200.318 states that the School must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: There was a lack of documentation and controls noted for two procurements, out of eight tested. For one of the procurements, the original signed quote was obtained, but no other documentation could be located. For the other contract, it started off as a small, verbal agreement several years ago and the related cleaning costs increased as the school grew over the years, with the only procurement documentation being signed annual agreements. Questioned costs: $56,110 for ALN 10.553 and 10.555 Context: Two of seven procurements tested were not supported by proper documentation detailing the complete history of the transaction or formal documentation of the controls in place over compliance to ensure the formal documentation of the reasoning for the procurement decision. Cause: The vendors had been used for several years and the amount of the related expenditures paid to the vendors increased with the School?s size and needs. Therefore, any formal documentation of the original procurement decision to use the vendor was no longer on file with the School. Effect: Lack of proper documentation of procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Uniform Guidance requires the School to have a written procurement policy per ?200.319. This policy should detail the method of procurement the School follows, including the School's micro-purchase threshold. Condition: The School has a written procurement policy, but it did not detail a micro-purchase threshold. Questioned costs: None Context: The School has a written procurement policy, but it did not detail its micro-purchase threshold. But it did note that it required bids for any contract over $25,000. Cause: The School was not aware that this requirement was missing from its current policy. Effect: The School is not in compliance with this policy requirement. This could result in the related procedures for procurements in amounts below their policy's requirement to obtain bids for contracts over $25,000 not being clear to School staff, which could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend that the School review its procurement policy for compliance with the Uniform Guidance and add a micro-purchase threshold to its procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 001 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: ?200.319 requires that all procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section and the School should have controls in place to ensure compliance with procurement requirements of the Child Nutrition Cluster program. Additionally, ?200.318 states that the School must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: There was a lack of documentation and controls noted for two procurements, out of eight tested. For one of the procurements, the original signed quote was obtained, but no other documentation could be located. For the other contract, it started off as a small, verbal agreement several years ago and the related cleaning costs increased as the school grew over the years, with the only procurement documentation being signed annual agreements. Questioned costs: $56,110 for ALN 10.553 and 10.555 Context: Two of seven procurements tested were not supported by proper documentation detailing the complete history of the transaction or formal documentation of the controls in place over compliance to ensure the formal documentation of the reasoning for the procurement decision. Cause: The vendors had been used for several years and the amount of the related expenditures paid to the vendors increased with the School?s size and needs. Therefore, any formal documentation of the original procurement decision to use the vendor was no longer on file with the School. Effect: Lack of proper documentation of procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553 & 10.555 Federal Award Identification Number and Year: S425V210045 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 212MN061N1199 Award Period: Fiscal Year Ended June 30, 2022 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Uniform Guidance requires the School to have a written procurement policy per ?200.319. This policy should detail the method of procurement the School follows, including the School's micro-purchase threshold. Condition: The School has a written procurement policy, but it did not detail a micro-purchase threshold. Questioned costs: None Context: The School has a written procurement policy, but it did not detail its micro-purchase threshold. But it did note that it required bids for any contract over $25,000. Cause: The School was not aware that this requirement was missing from its current policy. Effect: The School is not in compliance with this policy requirement. This could result in the related procedures for procurements in amounts below their policy's requirement to obtain bids for contracts over $25,000 not being clear to School staff, which could result in improper contracts being paid with federal funds. The School could also possibly award a contract to a vendor that would charge more than other responsible bidders. Repeat Finding: No Recommendation: We recommend that the School review its procurement policy for compliance with the Uniform Guidance and add a micro-purchase threshold to its procurement policy. Views of responsible officials: There is no disagreement with the audit finding.