Audit 55289

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS ? FEDERAL ALN 21.027 2022-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria ? 2 CFR ? 180 requires Independent School District No. 833 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including 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 within its coronavirus state and local fiscal recovery funds federal program 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. Our testing did not indicate any instances of noncompliance with these requirements. Context ? The District did not obtain the appropriate documentation for one of two vendors tested applicable to the coronavirus state and local fiscal recovery funds to ensure the vendor was not suspended or debarred from participation in federal program contracts. Repeat Finding ? This is a current year finding. Cause ? This was an oversight by district personnel. Effect ? Noncompliance with the suspension and debarment requirements could result in the District expending federal funds with 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 suspension and debarment for the coronavirus state and local fiscal recovery funds federal program. Internal controls over compliance for this area should include verification that 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 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.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCE OF NONCOMPLIANCE ? FEDERAL COMMUNICATIONS COMMISSION, EMERGENCY CONNECTIVITY FUND PROGRAM ? FEDERAL ALN 32.009 2022-003 Internal Control Over Compliance and Noncompliance With Special Tests and Provisions Requirements Criteria ? 47 CFR ? 54.1711 requires that the District only seek support for eligible equipment provided to students and school staff who would otherwise lack connected devices sufficient to engage in remote learning. Condition ? During our audit, we noted that the District did not have sufficient controls in place within its Emergency Connectivity Fund Program to assure compliance with federal special tests and provisions requirements. We noted that the District had requested reimbursement for all 2,560 devices, however, 124 of those devices were never used or deployed, and thus not meeting the definition of eligible equipment for which the District could seek reimbursement. Questioned Costs ? $34,720. Context ? Of the 2,560 devices, 124 were not eligible to be reimbursed. At the time of our audit, the District did not have documentation of deployment or use for 124 devices to support the required unmet need. Repeat Finding ? This is a current year finding. Cause ? This was an oversight by district personnel, due to unfamiliarity with a new federal program. Effect ? Noncompliance with the special tests and provisions requirements could be viewed as a violation of the award agreement and result in loss of funds. Recommendation ? We recommend that the District review its internal control procedures relating to special tests and provisions for the Emergency Connectivity Fund Program. The District should review the compliance guidance issued by the Federal Communications Commission to familiarize itself with federal compliance requirements specific to the Emergency Connectivity Fund Program. View of Responsible Official and Planned Corrective Actions ? The District agrees with the finding. The District intends to review its procedures relating to special tests and provisions requirements to ensure compliance in the future with any additional federal awards. The District has separately issued a Corrective Action Plan related to this finding.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS ? FEDERAL ALN 21.027 2022-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria ? 2 CFR ? 180 requires Independent School District No. 833 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including 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 within its coronavirus state and local fiscal recovery funds federal program 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. Our testing did not indicate any instances of noncompliance with these requirements. Context ? The District did not obtain the appropriate documentation for one of two vendors tested applicable to the coronavirus state and local fiscal recovery funds to ensure the vendor was not suspended or debarred from participation in federal program contracts. Repeat Finding ? This is a current year finding. Cause ? This was an oversight by district personnel. Effect ? Noncompliance with the suspension and debarment requirements could result in the District expending federal funds with 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 suspension and debarment for the coronavirus state and local fiscal recovery funds federal program. Internal controls over compliance for this area should include verification that 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 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.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCE OF NONCOMPLIANCE ? FEDERAL COMMUNICATIONS COMMISSION, EMERGENCY CONNECTIVITY FUND PROGRAM ? FEDERAL ALN 32.009 2022-003 Internal Control Over Compliance and Noncompliance With Special Tests and Provisions Requirements Criteria ? 47 CFR ? 54.1711 requires that the District only seek support for eligible equipment provided to students and school staff who would otherwise lack connected devices sufficient to engage in remote learning. Condition ? During our audit, we noted that the District did not have sufficient controls in place within its Emergency Connectivity Fund Program to assure compliance with federal special tests and provisions requirements. We noted that the District had requested reimbursement for all 2,560 devices, however, 124 of those devices were never used or deployed, and thus not meeting the definition of eligible equipment for which the District could seek reimbursement. Questioned Costs ? $34,720. Context ? Of the 2,560 devices, 124 were not eligible to be reimbursed. At the time of our audit, the District did not have documentation of deployment or use for 124 devices to support the required unmet need. Repeat Finding ? This is a current year finding. Cause ? This was an oversight by district personnel, due to unfamiliarity with a new federal program. Effect ? Noncompliance with the special tests and provisions requirements could be viewed as a violation of the award agreement and result in loss of funds. Recommendation ? We recommend that the District review its internal control procedures relating to special tests and provisions for the Emergency Connectivity Fund Program. The District should review the compliance guidance issued by the Federal Communications Commission to familiarize itself with federal compliance requirements specific to the Emergency Connectivity Fund Program. View of Responsible Official and Planned Corrective Actions ? The District agrees with the finding. The District intends to review its procedures relating to special tests and provisions requirements to ensure compliance in the future with any additional federal awards. The District has separately issued a Corrective Action Plan related to this finding.