Audit 9887

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.555C, 10.559 Federal Award Identification Number and Year: 202020N109942, 22MIN061N1199 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity 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. 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 School District did not perform the required verification procedures for two Child Nutrition Cluster covered transactions prior to entering into the contracts. The District did complete the verification procedures before entering into the related contracts, but the District did complete the procedures a few months after the contracts were awarded. Context: Of two covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications for either of the two covered transactions before entering into the related contracts. Questioned Costs: None Cause: Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.555C, 10.559 Federal Award Identification Number and Year: 202020N109942, 22MIN061N1199 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity 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. 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 School District did not perform the required verification procedures for two Child Nutrition Cluster covered transactions prior to entering into the contracts. The District did complete the verification procedures before entering into the related contracts, but the District did complete the procedures a few months after the contracts were awarded. Context: Of two covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications for either of the two covered transactions before entering into the related contracts. Questioned Costs: None Cause: Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.555C, 10.559 Federal Award Identification Number and Year: 202020N109942, 22MIN061N1199 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity 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. 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 School District did not perform the required verification procedures for two Child Nutrition Cluster covered transactions prior to entering into the contracts. The District did complete the verification procedures before entering into the related contracts, but the District did complete the procedures a few months after the contracts were awarded. Context: Of two covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications for either of the two covered transactions before entering into the related contracts. Questioned Costs: None Cause: Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.555C, 10.559 Federal Award Identification Number and Year: 202020N109942, 22MIN061N1199 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity 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. 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 School District did not perform the required verification procedures for two Child Nutrition Cluster covered transactions prior to entering into the contracts. The District did complete the verification procedures before entering into the related contracts, but the District did complete the procedures a few months after the contracts were awarded. Context: Of two covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications for either of the two covered transactions before entering into the related contracts. Questioned Costs: None Cause: Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.555C, 10.559 Federal Award Identification Number and Year: 202020N109942, 22MIN061N1199 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity 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. 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 School District did not perform the required verification procedures for two Child Nutrition Cluster covered transactions prior to entering into the contracts. The District did complete the verification procedures before entering into the related contracts, but the District did complete the procedures a few months after the contracts were awarded. Context: Of two covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications for either of the two covered transactions before entering into the related contracts. Questioned Costs: None Cause: Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity 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. 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 School District did not perform the required verification procedures over two covered transactions in fiscal year 2023. Context: Of two covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on either of the two covered transactions. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity 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. 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 School District did not perform the required verification procedures over two covered transactions in fiscal year 2023. Context: Of two covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on either of the two covered transactions. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity 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. 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 School District did not perform the required verification procedures over two covered transactions in fiscal year 2023. Context: Of two covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on either of the two covered transactions. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity 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. 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 School District did not perform the required verification procedures over two covered transactions in fiscal year 2023. Context: Of two covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on either of the two covered transactions. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.555C, 10.559 Federal Award Identification Number and Year: 202020N109942, 22MIN061N1199 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity 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. 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 School District did not perform the required verification procedures for two Child Nutrition Cluster covered transactions prior to entering into the contracts. The District did complete the verification procedures before entering into the related contracts, but the District did complete the procedures a few months after the contracts were awarded. Context: Of two covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications for either of the two covered transactions before entering into the related contracts. Questioned Costs: None Cause: Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.555C, 10.559 Federal Award Identification Number and Year: 202020N109942, 22MIN061N1199 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity 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. 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 School District did not perform the required verification procedures for two Child Nutrition Cluster covered transactions prior to entering into the contracts. The District did complete the verification procedures before entering into the related contracts, but the District did complete the procedures a few months after the contracts were awarded. Context: Of two covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications for either of the two covered transactions before entering into the related contracts. Questioned Costs: None Cause: Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.555C, 10.559 Federal Award Identification Number and Year: 202020N109942, 22MIN061N1199 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity 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. 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 School District did not perform the required verification procedures for two Child Nutrition Cluster covered transactions prior to entering into the contracts. The District did complete the verification procedures before entering into the related contracts, but the District did complete the procedures a few months after the contracts were awarded. Context: Of two covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications for either of the two covered transactions before entering into the related contracts. Questioned Costs: None Cause: Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.555C, 10.559 Federal Award Identification Number and Year: 202020N109942, 22MIN061N1199 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity 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. 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 School District did not perform the required verification procedures for two Child Nutrition Cluster covered transactions prior to entering into the contracts. The District did complete the verification procedures before entering into the related contracts, but the District did complete the procedures a few months after the contracts were awarded. Context: Of two covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications for either of the two covered transactions before entering into the related contracts. Questioned Costs: None Cause: Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.555C, 10.559 Federal Award Identification Number and Year: 202020N109942, 22MIN061N1199 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity 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. 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 School District did not perform the required verification procedures for two Child Nutrition Cluster covered transactions prior to entering into the contracts. The District did complete the verification procedures before entering into the related contracts, but the District did complete the procedures a few months after the contracts were awarded. Context: Of two covered transactions tested in the Child Nutrition Cluster, it was noted that the District did not perform the required verifications for either of the two covered transactions before entering into the related contracts. Questioned Costs: None Cause: Nutrition Services has limited ability to obtain food and materials due to supply chain issues. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate. Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented. Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502 Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method. Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented. Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs. Repeat Finding: Yes – 2022-002. Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity 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. 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 School District did not perform the required verification procedures over two covered transactions in fiscal year 2023. Context: Of two covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on either of the two covered transactions. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity 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. 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 School District did not perform the required verification procedures over two covered transactions in fiscal year 2023. Context: Of two covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on either of the two covered transactions. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity 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. 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 School District did not perform the required verification procedures over two covered transactions in fiscal year 2023. Context: Of two covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on either of the two covered transactions. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.

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: H027A210087 and H173A180086 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: Fiscal Year 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity 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. 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 School District did not perform the required verification procedures over two covered transactions in fiscal year 2023. Context: Of two covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on either of the two covered transactions. Questioned Costs: None Cause: The District has had turnover in some roles within the Special Education program. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2022-003 Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. View of Responsible Official: There is no disagreement with the audit finding.