Audit 395812

CHILD NUTRITION CLUSTER – SUSPENSION AND DEBARMENT U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The covered transactions which were tested did not have documentation the District performed the required verification. Context: The District did not perform the required verification procedures over 2 out of 5 covered transactions in fiscal year 2025. Questioned costs: None Cause: The District has no policy formalizing the suspension and debarment procedures and controls. Effect: A lack of updated policies and suspension and debarment procedures being performed could lead to the District entering into a covered transaction with a suspended or debarred vendor. Repeat finding: Yes – 2024-013. Recommendation: We recommend the District formalizes their suspension & debarment procedures in a policy and ensure they check suspension and debarment for all vendors prior to entering into a covered transaction. Views of responsible officials: There is no disagreement with the finding.

SPECIAL EDUCATION CLUSTER – SUSPENSION AND DEBARMENT U.S. Department of Education Special Education Cluster Assistance Listing Number: 84.027 & 84.173 Passed Through Minnesota Department of Education Pass Through Number: H027A220087 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The covered transactions which were tested did not have documentation the District performed the required verification. Context: The District did not perform the required verification procedures over 1 out of 1 covered transactions in fiscal year 2025. Questioned costs: None Cause: The District has no policy formalizing the suspension and debarment procedures and controls. Effect: A lack of policies and suspension and debarment procedures being performed could lead to the District entering into a covered transaction with a suspended or debarred vendor. Repeat finding: Yes – 2024-010. Recommendation: We recommend the District formalize their suspension and debarment procedures in a policy and ensure they check suspension and debarment for all vendors prior to entering into a covered transaction. Views of responsible officials: There is no disagreement with the finding.