Finding 2022-003 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR ? 180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that 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. Condition: In our testing for the Special Education Cluster, we noted instances where there was no documentation of this verification being performed. Questioned Costs: None Context: During testing of the program, it was noted that five of seven contacts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government. Cause: The District?s practice of ensuring sam.gov was checked for all contracts entered into and documentation retained was not performed as expected during the pandemic, and shortly thereafter during fiscal year 2022. Effect: The District was not in compliance with federal suspension and debarment requirements. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-010 in the previous report for fiscal year 2021. Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-004 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 84.027 - $173,812.24. Context: Out of seven procurement which were tested, we noted five of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. Cause: The District during the pandemic and shortly thereafter, was not able to properly ensure all contracts has procurement documentation retained and performed as required by the Uniform Guidance. Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-012 in the previous report for fiscal year 2021. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-005 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Questioned Costs: ALN 84.027? Known $2,884 Context: Of a sample of 40 payroll disbursement charged to the grant we noted one disbursement which was not properly supported by time and effort documentation and one disbursement where documentation of the approval of the rate paid was not provided. Cause: The District was not documenting time and effort for this individual as their wages were initially coded to FIN 161 during the year. The District thought the special education department would be tracking time and effort but the special education department only determined who should be tracked based on the finance code that the employee was coded to for payroll. The employee paid an incorrect amount was paid a wage of $25, which has historically been what interpreters are paid, however there was no documentation available to show that amount was approved. Effect: The District was not in compliance with time and effort documentation requirements of the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the District reviews its procedures for charging wages and benefits to federal grants to ensure all are properly supported by time and effort documentation. Views of responsible officials: There is no disagreement with the finding.
Finding 2022-003 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR ? 180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that 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. Condition: In our testing for the Special Education Cluster, we noted instances where there was no documentation of this verification being performed. Questioned Costs: None Context: During testing of the program, it was noted that five of seven contacts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government. Cause: The District?s practice of ensuring sam.gov was checked for all contracts entered into and documentation retained was not performed as expected during the pandemic, and shortly thereafter during fiscal year 2022. Effect: The District was not in compliance with federal suspension and debarment requirements. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-010 in the previous report for fiscal year 2021. Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-004 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 84.027 - $173,812.24. Context: Out of seven procurement which were tested, we noted five of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. Cause: The District during the pandemic and shortly thereafter, was not able to properly ensure all contracts has procurement documentation retained and performed as required by the Uniform Guidance. Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-012 in the previous report for fiscal year 2021. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-005 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Questioned Costs: ALN 84.027? Known $2,884 Context: Of a sample of 40 payroll disbursement charged to the grant we noted one disbursement which was not properly supported by time and effort documentation and one disbursement where documentation of the approval of the rate paid was not provided. Cause: The District was not documenting time and effort for this individual as their wages were initially coded to FIN 161 during the year. The District thought the special education department would be tracking time and effort but the special education department only determined who should be tracked based on the finance code that the employee was coded to for payroll. The employee paid an incorrect amount was paid a wage of $25, which has historically been what interpreters are paid, however there was no documentation available to show that amount was approved. Effect: The District was not in compliance with time and effort documentation requirements of the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the District reviews its procedures for charging wages and benefits to federal grants to ensure all are properly supported by time and effort documentation. Views of responsible officials: There is no disagreement with the finding.
Finding 2022-003 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR ? 180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that 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. Condition: In our testing for the Special Education Cluster, we noted instances where there was no documentation of this verification being performed. Questioned Costs: None Context: During testing of the program, it was noted that five of seven contacts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government. Cause: The District?s practice of ensuring sam.gov was checked for all contracts entered into and documentation retained was not performed as expected during the pandemic, and shortly thereafter during fiscal year 2022. Effect: The District was not in compliance with federal suspension and debarment requirements. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-010 in the previous report for fiscal year 2021. Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-004 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 84.027 - $173,812.24. Context: Out of seven procurement which were tested, we noted five of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. Cause: The District during the pandemic and shortly thereafter, was not able to properly ensure all contracts has procurement documentation retained and performed as required by the Uniform Guidance. Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-012 in the previous report for fiscal year 2021. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-005 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Questioned Costs: ALN 84.027? Known $2,884 Context: Of a sample of 40 payroll disbursement charged to the grant we noted one disbursement which was not properly supported by time and effort documentation and one disbursement where documentation of the approval of the rate paid was not provided. Cause: The District was not documenting time and effort for this individual as their wages were initially coded to FIN 161 during the year. The District thought the special education department would be tracking time and effort but the special education department only determined who should be tracked based on the finance code that the employee was coded to for payroll. The employee paid an incorrect amount was paid a wage of $25, which has historically been what interpreters are paid, however there was no documentation available to show that amount was approved. Effect: The District was not in compliance with time and effort documentation requirements of the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the District reviews its procedures for charging wages and benefits to federal grants to ensure all are properly supported by time and effort documentation. Views of responsible officials: There is no disagreement with the finding.
Finding 2022-003 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR ? 180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that 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. Condition: In our testing for the Special Education Cluster, we noted instances where there was no documentation of this verification being performed. Questioned Costs: None Context: During testing of the program, it was noted that five of seven contacts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government. Cause: The District?s practice of ensuring sam.gov was checked for all contracts entered into and documentation retained was not performed as expected during the pandemic, and shortly thereafter during fiscal year 2022. Effect: The District was not in compliance with federal suspension and debarment requirements. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-010 in the previous report for fiscal year 2021. Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-004 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 84.027 - $173,812.24. Context: Out of seven procurement which were tested, we noted five of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. Cause: The District during the pandemic and shortly thereafter, was not able to properly ensure all contracts has procurement documentation retained and performed as required by the Uniform Guidance. Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-012 in the previous report for fiscal year 2021. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-005 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Questioned Costs: ALN 84.027? Known $2,884 Context: Of a sample of 40 payroll disbursement charged to the grant we noted one disbursement which was not properly supported by time and effort documentation and one disbursement where documentation of the approval of the rate paid was not provided. Cause: The District was not documenting time and effort for this individual as their wages were initially coded to FIN 161 during the year. The District thought the special education department would be tracking time and effort but the special education department only determined who should be tracked based on the finance code that the employee was coded to for payroll. The employee paid an incorrect amount was paid a wage of $25, which has historically been what interpreters are paid, however there was no documentation available to show that amount was approved. Effect: The District was not in compliance with time and effort documentation requirements of the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the District reviews its procedures for charging wages and benefits to federal grants to ensure all are properly supported by time and effort documentation. Views of responsible officials: There is no disagreement with the finding.
Finding 2022-003 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR ? 180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that 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. Condition: In our testing for the Special Education Cluster, we noted instances where there was no documentation of this verification being performed. Questioned Costs: None Context: During testing of the program, it was noted that five of seven contacts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government. Cause: The District?s practice of ensuring sam.gov was checked for all contracts entered into and documentation retained was not performed as expected during the pandemic, and shortly thereafter during fiscal year 2022. Effect: The District was not in compliance with federal suspension and debarment requirements. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-010 in the previous report for fiscal year 2021. Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-004 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 84.027 - $173,812.24. Context: Out of seven procurement which were tested, we noted five of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. Cause: The District during the pandemic and shortly thereafter, was not able to properly ensure all contracts has procurement documentation retained and performed as required by the Uniform Guidance. Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-012 in the previous report for fiscal year 2021. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-005 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Questioned Costs: ALN 84.027? Known $2,884 Context: Of a sample of 40 payroll disbursement charged to the grant we noted one disbursement which was not properly supported by time and effort documentation and one disbursement where documentation of the approval of the rate paid was not provided. Cause: The District was not documenting time and effort for this individual as their wages were initially coded to FIN 161 during the year. The District thought the special education department would be tracking time and effort but the special education department only determined who should be tracked based on the finance code that the employee was coded to for payroll. The employee paid an incorrect amount was paid a wage of $25, which has historically been what interpreters are paid, however there was no documentation available to show that amount was approved. Effect: The District was not in compliance with time and effort documentation requirements of the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the District reviews its procedures for charging wages and benefits to federal grants to ensure all are properly supported by time and effort documentation. Views of responsible officials: There is no disagreement with the finding.
Finding 2022-003 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR ? 180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District must verify that 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. Condition: In our testing for the Special Education Cluster, we noted instances where there was no documentation of this verification being performed. Questioned Costs: None Context: During testing of the program, it was noted that five of seven contacts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government. Cause: The District?s practice of ensuring sam.gov was checked for all contracts entered into and documentation retained was not performed as expected during the pandemic, and shortly thereafter during fiscal year 2022. Effect: The District was not in compliance with federal suspension and debarment requirements. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-010 in the previous report for fiscal year 2021. Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-004 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 84.027 - $173,812.24. Context: Out of seven procurement which were tested, we noted five of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. Cause: The District during the pandemic and shortly thereafter, was not able to properly ensure all contracts has procurement documentation retained and performed as required by the Uniform Guidance. Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-012 in the previous report for fiscal year 2021. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-005 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: During our testing of a sample of payroll transactions charged to the grant we noted not all transactions were supported by properly approved documentation. Questioned Costs: ALN 84.027? Known $2,884 Context: Of a sample of 40 payroll disbursement charged to the grant we noted one disbursement which was not properly supported by time and effort documentation and one disbursement where documentation of the approval of the rate paid was not provided. Cause: The District was not documenting time and effort for this individual as their wages were initially coded to FIN 161 during the year. The District thought the special education department would be tracking time and effort but the special education department only determined who should be tracked based on the finance code that the employee was coded to for payroll. The employee paid an incorrect amount was paid a wage of $25, which has historically been what interpreters are paid, however there was no documentation available to show that amount was approved. Effect: The District was not in compliance with time and effort documentation requirements of the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the District reviews its procedures for charging wages and benefits to federal grants to ensure all are properly supported by time and effort documentation. Views of responsible officials: There is no disagreement with the finding.