MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027
2024-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, and Suspension and Debarment Requirements
Criteria – 2 CFR § 180 and 2 CFR § 200.318-327 requires Northeast Metropolitan Intermediate School District No. 916 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, and suspension and debarment requirements applicable to the coronavirus state and local fiscal recovery funds federal program.
Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its coronavirus state and local fiscal recovery funds federal program to ensure compliance with federal procurement requirements related to methods of procurement and to assure that 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.
Context – For nine of nine vendors exceeding the micro-purchase threshold, the District did not document its compliance with procurement policies and Uniform Guidance requirements related to methods of procurement, and documentation of compliance with suspension and debarment requirements was not maintained for four of four vendors tested to ensure compliance with this requirement in the current year. This was not a statistically valid sample.
Repeat Finding – This is a current and prior year finding.
Cause – This was an oversight by district personnel.
Effect – Noncompliance with procurement, and suspension and debarment 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 procurement, and suspension and debarment for the coronavirus state and local fiscal recovery funds federal program. Internal controls over compliance for this area should include documentation of procurement policies and Uniform Guidance requirements related to methods of procurement verification. These controls should also include steps to ensure 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 procurement, and suspension and debarment for its 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.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – EDUCATION STABILIZATION FUND – FEDERAL ALN 84.425
2024-002 Internal Control Over Compliance and Material Noncompliance With Special Tests and Provisions Over Wage Rate Requirements
Criteria – 29CFR part 5 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including wage reate requirements applicable to the education stabilization fund.
Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its educaiton stabilization fund federal program to ensure compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Questioned Costs – None.
Context – The District did not have any policies in place regarding wage rate requirements and did not have the proper documentation of compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Repeat Finding – This is a current year finding.
Cause – This was an oversight by district personnel.
Effect – Noncompliance with wage rate requirements could result in the District not paying wages on these contracts that are required to meet Davis-Bacon Act prevailing wage rate requirements.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – EDUCATION STABILIZATION FUND – FEDERAL ALN 84.425
2024-002 Internal Control Over Compliance and Material Noncompliance With Special Tests and Provisions Over Wage Rate Requirements
Criteria – 29CFR part 5 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including wage reate requirements applicable to the education stabilization fund.
Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its educaiton stabilization fund federal program to ensure compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Questioned Costs – None.
Context – The District did not have any policies in place regarding wage rate requirements and did not have the proper documentation of compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Repeat Finding – This is a current year finding.
Cause – This was an oversight by district personnel.
Effect – Noncompliance with wage rate requirements could result in the District not paying wages on these contracts that are required to meet Davis-Bacon Act prevailing wage rate requirements.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – EDUCATION STABILIZATION FUND – FEDERAL ALN 84.425
2024-002 Internal Control Over Compliance and Material Noncompliance With Special Tests and Provisions Over Wage Rate Requirements
Criteria – 29CFR part 5 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including wage reate requirements applicable to the education stabilization fund.
Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its educaiton stabilization fund federal program to ensure compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Questioned Costs – None.
Context – The District did not have any policies in place regarding wage rate requirements and did not have the proper documentation of compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Repeat Finding – This is a current year finding.
Cause – This was an oversight by district personnel.
Effect – Noncompliance with wage rate requirements could result in the District not paying wages on these contracts that are required to meet Davis-Bacon Act prevailing wage rate requirements.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027
2024-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, and Suspension and Debarment Requirements
Criteria – 2 CFR § 180 and 2 CFR § 200.318-327 requires Northeast Metropolitan Intermediate School District No. 916 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, and suspension and debarment requirements applicable to the coronavirus state and local fiscal recovery funds federal program.
Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its coronavirus state and local fiscal recovery funds federal program to ensure compliance with federal procurement requirements related to methods of procurement and to assure that 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.
Context – For nine of nine vendors exceeding the micro-purchase threshold, the District did not document its compliance with procurement policies and Uniform Guidance requirements related to methods of procurement, and documentation of compliance with suspension and debarment requirements was not maintained for four of four vendors tested to ensure compliance with this requirement in the current year. This was not a statistically valid sample.
Repeat Finding – This is a current and prior year finding.
Cause – This was an oversight by district personnel.
Effect – Noncompliance with procurement, and suspension and debarment 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 procurement, and suspension and debarment for the coronavirus state and local fiscal recovery funds federal program. Internal controls over compliance for this area should include documentation of procurement policies and Uniform Guidance requirements related to methods of procurement verification. These controls should also include steps to ensure 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 procurement, and suspension and debarment for its 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.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – EDUCATION STABILIZATION FUND – FEDERAL ALN 84.425
2024-002 Internal Control Over Compliance and Material Noncompliance With Special Tests and Provisions Over Wage Rate Requirements
Criteria – 29CFR part 5 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including wage reate requirements applicable to the education stabilization fund.
Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its educaiton stabilization fund federal program to ensure compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Questioned Costs – None.
Context – The District did not have any policies in place regarding wage rate requirements and did not have the proper documentation of compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Repeat Finding – This is a current year finding.
Cause – This was an oversight by district personnel.
Effect – Noncompliance with wage rate requirements could result in the District not paying wages on these contracts that are required to meet Davis-Bacon Act prevailing wage rate requirements.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – EDUCATION STABILIZATION FUND – FEDERAL ALN 84.425
2024-002 Internal Control Over Compliance and Material Noncompliance With Special Tests and Provisions Over Wage Rate Requirements
Criteria – 29CFR part 5 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including wage reate requirements applicable to the education stabilization fund.
Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its educaiton stabilization fund federal program to ensure compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Questioned Costs – None.
Context – The District did not have any policies in place regarding wage rate requirements and did not have the proper documentation of compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Repeat Finding – This is a current year finding.
Cause – This was an oversight by district personnel.
Effect – Noncompliance with wage rate requirements could result in the District not paying wages on these contracts that are required to meet Davis-Bacon Act prevailing wage rate requirements.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – EDUCATION STABILIZATION FUND – FEDERAL ALN 84.425
2024-002 Internal Control Over Compliance and Material Noncompliance With Special Tests and Provisions Over Wage Rate Requirements
Criteria – 29CFR part 5 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including wage reate requirements applicable to the education stabilization fund.
Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its educaiton stabilization fund federal program to ensure compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Questioned Costs – None.
Context – The District did not have any policies in place regarding wage rate requirements and did not have the proper documentation of compliance with wage rate requirements related to minor remodeling, renovation, or construction contracts that are over $2,000 that use laborers and mechanics that are required to meet Davis-Bacon Act prevailing wage rate requirements.
Repeat Finding – This is a current year finding.
Cause – This was an oversight by district personnel.
Effect – Noncompliance with wage rate requirements could result in the District not paying wages on these contracts that are required to meet Davis-Bacon Act prevailing wage rate requirements.