Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the College would be able to timely return the money prior to 240 days after issuance of the check. Questioned Costs: None Context: During our testing, it was noted the College did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. During our testing of outstanding checks, we did not note any checks that were out of compliance with this requirement. Cause: The College did not have a process in place to specifically monitor the federal checks throughout the year. Effect: The College is not in compliance with Department of Education requirements. Repeat Finding: No. Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the College would be able to timely return the money prior to 240 days after issuance of the check. Questioned Costs: None Context: During our testing, it was noted the College did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. During our testing of outstanding checks, we did not note any checks that were out of compliance with this requirement. Cause: The College did not have a process in place to specifically monitor the federal checks throughout the year. Effect: The College is not in compliance with Department of Education requirements. Repeat Finding: No. Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the College did not report the correct status and effective dates, enrollment was not certified timely, and the status changes were not always reported timely. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned Costs: None Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 4 students where the campus enrollment status was not reported correctly, 6 students where the enrollment effective date was not reported correctly, 57 students where the enrollment was not reported timely to NSLDS, and 60 students where enrollment was not certified every 60 days. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, Prior year finding 2023-004. Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the College did not report the correct status and effective dates, enrollment was not certified timely, and the status changes were not always reported timely. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned Costs: None Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 4 students where the campus enrollment status was not reported correctly, 6 students where the enrollment effective date was not reported correctly, 57 students where the enrollment was not reported timely to NSLDS, and 60 students where enrollment was not certified every 60 days. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, Prior year finding 2023-004. Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the College did not report the correct status and effective dates, enrollment was not certified timely, and the status changes were not always reported timely. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned Costs: None Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 4 students where the campus enrollment status was not reported correctly, 6 students where the enrollment effective date was not reported correctly, 57 students where the enrollment was not reported timely to NSLDS, and 60 students where enrollment was not certified every 60 days. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, Prior year finding 2023-004. Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the College did not report the correct status and effective dates, enrollment was not certified timely, and the status changes were not always reported timely. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned Costs: None Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 4 students where the campus enrollment status was not reported correctly, 6 students where the enrollment effective date was not reported correctly, 57 students where the enrollment was not reported timely to NSLDS, and 60 students where enrollment was not certified every 60 days. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, Prior year finding 2023-004. Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: Yes. Prior year finding 2023-005. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: Yes. Prior year finding 2023-005. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: Yes. Prior year finding 2023-005. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: Yes. Prior year finding 2023-005. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: The College did not provide the URL for the contract or cost information to the Department of Education. Questioned Costs: None Context: The College did not meet the compliance requirement to report the URL for the contract and cost information to the Department of Education. Cause: The College did not have proper procedures in place to ensure that all requirements were being met. Effect: The College is not in compliance with disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: Yes, Prior year finding 2023-006. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: The College did not provide the URL for the contract or cost information to the Department of Education. Questioned Costs: None Context: The College did not meet the compliance requirement to report the URL for the contract and cost information to the Department of Education. Cause: The College did not have proper procedures in place to ensure that all requirements were being met. Effect: The College is not in compliance with disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: Yes, Prior year finding 2023-006. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: The College did not provide the URL for the contract or cost information to the Department of Education. Questioned Costs: None Context: The College did not meet the compliance requirement to report the URL for the contract and cost information to the Department of Education. Cause: The College did not have proper procedures in place to ensure that all requirements were being met. Effect: The College is not in compliance with disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: Yes, Prior year finding 2023-006. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-002 – Procurement, Suspension, and Debarment Identification of the federal program: Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.493, Congressional Directives Federal Award Number: 1 CE1HS52357‐01‐00 Federal Award Period of Performance: 09/30/2023–09/29/2026 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Procurement policies required by 2 CFR 200.318-326 were not formally documented. Documentation was not consistently retained evidencing the review and approval of new vendors for suspension and debarment prior to adding them into PeopleSoft, CFNI’s vendor management platform. Management represented that they performed a monthly reconciliation of the number of vendors screened and the number of vendors submitted to the third-party, however, management did not retain evidence of the reviews in fiscal year 2024. CFNI’s third-party contractor for suspension and debarment does not have a SOC 1 (System and Organization Controls Report) report that covers the controls over suspension and debarment services provided. Management did not perform testing over the results of the third-party contractor to assess the accuracy of its procedures. Effect or potential effect: Suspension and debarment results provided by the third-party contractor may not be accurate. As a result, federal funds may be used to pay a contractor that is suspended or debarred. Questioned costs: None. Context: For three of 40 new vendors sampled during the fiscal year, the documentation evidencing the review of new vendors for suspension and debarment was not retained. For Assistance Listing No. 93.493, the federal portion of procurement expenditures subject to suspension and debarment review totaled $1,441,622, which represents approximately 61.5% of total federal expenditures of $2,341,797 reported in the SEFA for the year ended June 30, 2024. Identification as a repeat finding, if applicable: This is not a repeat finding from the prior year. Recommendation: CFNI should revise its procurement policies to be in compliance with 2 CFR 200.318-326. CFNI should implement procedures to reperform the testing for a sample of vendors from the third-party suspension and debarment results to ensure the accuracy of the results received. CFNI should formalize the documentation of the reconciliation of the number of vendors screened and the number of vendors submitted to the third-party. CFNI should update its policies and procedures over the new vendor setup process to require supporting documentation related to the suspension and debarment search performed be maintained. Views of responsible officials: The audit identified three instances out of 40 sampled where CFNI did not retain documentation verifying that suspension and debarment reviews were conducted during the onboarding of new suppliers. Although CFNI has an established vetting process, it recognizes the need for consistent documentation to evidence compliance. CFNI will implement formalized procedures to ensure all suspension and debarment reviews are documented and retained for audit purposes. CFNI engages a third-party contractor to monitor its supplier list against suspension and debarment databases. While the vendor provided a SOC 1 report, it did not specifically cover the suspension and debarment services provided. Additionally, CFNI did not conduct testing to validate the accuracy of the third-party's results. CFNI will revise its vendor management practices to ensure the SOC 1 reports cover the relevant services, and it will establish testing procedures to confirm the reliability of the vendor's outputs. Although CFNI utilizes two processes to monitor active suppliers against suspension and debarment lists, no reconciliation was documented to confirm that the supplier lists provided to and received from the third party were complete and accurate. Additionally, no testing was conducted to validate the third party’s work. CFNI will implement a reconciliation process to verify the completeness and accuracy of supplier lists before and after third-party reviews. Furthermore, it will establish a sampling and testing procedure to validate the results provided by external vendors.
Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: Criteria Per 2 CFR 200.303: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: Criteria Per 2 CFR 200.303: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: Criteria Per 2 CFR 200.303: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: Criteria Per 2 CFR 200.303: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Programs Affected U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2023 – June 30, 2024: Criteria Per 2 CFR 200.303: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition While testing return of Title IV funds (R2T4), a nonstatistical sample of 25 students was tested for proper return calculations. The University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. Cause The University process was to perform a documented review of R2T4 calculations only when a student was determined not to have earned 100% of their aid, and thus the documented review was not completed for the 2 of 25 calculations sampled. Questioned Costs None. Effect Without proper review, an error in the R2T4 calculation could be missed, causing incorrect refunds and non-compliance with regulations. Identification as a Repeat Finding, if Applicable Not applicable. Recommendation BD recommends the process be revised to require review of the R2T4 calculations regardless of determined aid earned percentage. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Assistance listing number: 10.553 & 10.555 Program title: Child Nutrition Cluster Agency: U.S. Department of Agriculture Pass-Through entity: Missouri Department of Elementary and Secondary Education Compliance Requirement: Eligibility Type of Finding: Material noncompliance Criteria: The Uniform Guidance (2 CFR section 200.303) requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: There were errors in the determination of eligibility of students to receive free and reduced meals. Cause: During the year, there was no second review of the determination of student eligibility to receive free or reduced priced meals. Effect: Due to the lack of effective internal control, errors were noted causing the school to overclaim eligible meals. Questioned costs: $20,578.74 Recommendation: We recommend the School evaluate the key processes, identify risks in existing in the Child Nutrition Cluster and implement internal controls to respond to the identified risks. Views of responsible officials: The School agrees with the finding and will implement the auditor’s recommendation.
Assistance listing number: 10.553 & 10.555 Program title: Child Nutrition Cluster Agency: U.S. Department of Agriculture Pass-Through entity: Missouri Department of Elementary and Secondary Education Compliance Requirement: Eligibility Type of Finding: Material noncompliance Criteria: The Uniform Guidance (2 CFR section 200.303) requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: There were errors in the determination of eligibility of students to receive free and reduced meals. Cause: During the year, there was no second review of the determination of student eligibility to receive free or reduced priced meals. Effect: Due to the lack of effective internal control, errors were noted causing the school to overclaim eligible meals. Questioned costs: $20,578.74 Recommendation: We recommend the School evaluate the key processes, identify risks in existing in the Child Nutrition Cluster and implement internal controls to respond to the identified risks. Views of responsible officials: The School agrees with the finding and will implement the auditor’s recommendation.
Program: Targeted Airshed Grant Program Federal Financial Assistance Listing Number: 66.956 Federal Grantor: Environmental Protection Agency Award Year: 4/15/2021-4/30/2026; 5/1/2022-4/30/2027 Grant Award Number: TA98T10501; TA98T36001 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the District must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2024 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: As a result of our testwork, we noted three (3) out of three (3) instances where there was no evidence that the District verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. However, none of the payments in our sample were made to a suspended or debarred party. Cause: The District did not have policies and procedures in place to verify the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. Effect: The District lacked documentation to support compliance with suspension and debarment requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Suspension and debarment was applicable to 3 subrecipients. We tested all 3 subrecipients during the year. Repeat Finding from Prior Years: No. Recommendation: We recommend that the District implement procedures to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Targeted Airshed Grant Program Federal Financial Assistance Listing Number: 66.956 Federal Grantor: Environmental Protection Agency Award Year: 4/15/2021-4/30/2026; 5/1/2022-4/30/2027 Grant Award Number: TA98T10501; TA98T36001 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the District must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2024 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: As a result of our testwork, we noted three (3) out of three (3) instances where there was no evidence that the District verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. However, none of the payments in our sample were made to a suspended or debarred party. Cause: The District did not have policies and procedures in place to verify the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. Effect: The District lacked documentation to support compliance with suspension and debarment requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Suspension and debarment was applicable to 3 subrecipients. We tested all 3 subrecipients during the year. Repeat Finding from Prior Years: No. Recommendation: We recommend that the District implement procedures to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal 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 District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal 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 District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal 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 District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal 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 District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 006: Procurement Federal Agencies: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, and 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District did not retain formal documentation of controls over procurement procedures over covered transactions in the child nutrition program in 2024. Questioned Costs: None Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 2 of 40 items tested for the child nutrition program. Cause: Although it was determined that compliance requirements were met through corroboration with multiple District staff and contractors as well as confirmation that one of the noted procurements in question was purchased through a group purchasing cooperation, the documentation of related controls was not formally documented or retained. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 006: Procurement Federal Agencies: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, and 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District did not retain formal documentation of controls over procurement procedures over covered transactions in the child nutrition program in 2024. Questioned Costs: None Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 2 of 40 items tested for the child nutrition program. Cause: Although it was determined that compliance requirements were met through corroboration with multiple District staff and contractors as well as confirmation that one of the noted procurements in question was purchased through a group purchasing cooperation, the documentation of related controls was not formally documented or retained. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 006: Procurement Federal Agencies: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, and 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District did not retain formal documentation of controls over procurement procedures over covered transactions in the child nutrition program in 2024. Questioned Costs: None Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 2 of 40 items tested for the child nutrition program. Cause: Although it was determined that compliance requirements were met through corroboration with multiple District staff and contractors as well as confirmation that one of the noted procurements in question was purchased through a group purchasing cooperation, the documentation of related controls was not formally documented or retained. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 006: Procurement Federal Agencies: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, and 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District did not retain formal documentation of controls over procurement procedures over covered transactions in the child nutrition program in 2024. Questioned Costs: None Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 2 of 40 items tested for the child nutrition program. Cause: Although it was determined that compliance requirements were met through corroboration with multiple District staff and contractors as well as confirmation that one of the noted procurements in question was purchased through a group purchasing cooperation, the documentation of related controls was not formally documented or retained. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal 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 District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal 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 District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 006: Procurement Federal Agencies: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, and 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District did not retain formal documentation of controls over procurement procedures over covered transactions in the child nutrition program in 2024. Questioned Costs: None Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 2 of 40 items tested for the child nutrition program. Cause: Although it was determined that compliance requirements were met through corroboration with multiple District staff and contractors as well as confirmation that one of the noted procurements in question was purchased through a group purchasing cooperation, the documentation of related controls was not formally documented or retained. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 006: Procurement Federal Agencies: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, and 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District did not retain formal documentation of controls over procurement procedures over covered transactions in the child nutrition program in 2024. Questioned Costs: None Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 2 of 40 items tested for the child nutrition program. Cause: Although it was determined that compliance requirements were met through corroboration with multiple District staff and contractors as well as confirmation that one of the noted procurements in question was purchased through a group purchasing cooperation, the documentation of related controls was not formally documented or retained. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 005: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Special Education Cluster ALN: 84.027 and 84.173 Federal Award Identification Numbers and Year: H027A230087 & H173A230086, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A230087 & H173A230086 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Special Education Cluster, 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 District did not perform the required verification procedures before entering into over covered transactions in the special education program for fiscal year 2024, and the District therefore also did not retain documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of two covered transactions tested, it was noted that the District did not perform the required control over verifications on two of two. It was noted during testing and review of SAM.gov, however, that none of the vendors used were suspended or debarred. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 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. Also, the District should ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 007: Procurement Federal Agency: U.S. Department of Education Federal Program Title: Special Education Cluster ALN: 84.027 and 84.173 Federal Award Identification Numbers and Year: H027A230087 & H173A230086, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A230087 & H173A230086 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District did not perform the required control over procurement procedures over covered transactions in the special education program in 2024. Questioned Costs: $19,317 Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 3 of 3 items tested for the special education program. Cause: District did not retain the proper documentation for the procurement method utilized. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 005: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Special Education Cluster ALN: 84.027 and 84.173 Federal Award Identification Numbers and Year: H027A230087 & H173A230086, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A230087 & H173A230086 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Special Education Cluster, 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 District did not perform the required verification procedures before entering into over covered transactions in the special education program for fiscal year 2024, and the District therefore also did not retain documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of two covered transactions tested, it was noted that the District did not perform the required control over verifications on two of two. It was noted during testing and review of SAM.gov, however, that none of the vendors used were suspended or debarred. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 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. Also, the District should ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
2024 - 007: Procurement Federal Agency: U.S. Department of Education Federal Program Title: Special Education Cluster ALN: 84.027 and 84.173 Federal Award Identification Numbers and Year: H027A230087 & H173A230086, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A230087 & H173A230086 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District did not perform the required control over procurement procedures over covered transactions in the special education program in 2024. Questioned Costs: $19,317 Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 3 of 3 items tested for the special education program. Cause: District did not retain the proper documentation for the procurement method utilized. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2024-678022-DPI-SB-546, 2024-010014-DPI-NSL-547, 2024-010014-DPISK_NSLAE-566 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria: According to 2 CFR, Part 200.303 of the Office of Management and Budget’s Uniform Grant Guidance, a non-Federal entity must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition: One City Schools, Inc. did not have a process in place to review funding claims prior to submission. Questioned costs: None Context: We sampled 4 monthly funding claims, noting that all were reviewed subsequent to submission. Cause: Policies and procedures were put in place after the prior year single audit findings, but were not able to be incorporated for the current fiscal year under audit. Effect: Incomplete or inaccurate information could be reported on funding claims. Repeat Finding: Yes (2023-006) Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Views of responsible officials: One City Schools, Inc. agrees with the finding and are working on implementing policies and procedures over reviewing claims prior to submission.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2024-678022-DPI-SB-546, 2024-010014-DPI-NSL-547, 2024-010014-DPISK_NSLAE-566 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria: According to 2 CFR, Part 200.303 of the Office of Management and Budget’s Uniform Grant Guidance, a non-Federal entity must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition: One City Schools, Inc. did not have a process in place to review funding claims prior to submission. Questioned costs: None Context: We sampled 4 monthly funding claims, noting that all were reviewed subsequent to submission. Cause: Policies and procedures were put in place after the prior year single audit findings, but were not able to be incorporated for the current fiscal year under audit. Effect: Incomplete or inaccurate information could be reported on funding claims. Repeat Finding: Yes (2023-006) Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Views of responsible officials: One City Schools, Inc. agrees with the finding and are working on implementing policies and procedures over reviewing claims prior to submission.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2024-678022-DPI-SB-546, 2024-010014-DPI-NSL-547, 2024-010014-DPISK_NSLAE-566 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria: According to 2 CFR, Part 200.303 of the Office of Management and Budget’s Uniform Grant Guidance, a non-Federal entity must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition: One City Schools, Inc. did not have a process in place to review funding claims prior to submission. Questioned costs: None Context: We sampled 4 monthly funding claims, noting that all were reviewed subsequent to submission. Cause: Policies and procedures were put in place after the prior year single audit findings, but were not able to be incorporated for the current fiscal year under audit. Effect: Incomplete or inaccurate information could be reported on funding claims. Repeat Finding: Yes (2023-006) Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Views of responsible officials: One City Schools, Inc. agrees with the finding and are working on implementing policies and procedures over reviewing claims prior to submission.
ALN #93.788: Opioid State Targeted Response Pass through: Central Florida Behavioral Health Network, Lutheran Services, and Florida Alcohol and Drug Abuse Association Contract Number: QG034, ME056, DCF MOA Compliance Requirements: Suspension and Debarment Questioned Costs: N/A Criteria: 2 CFR 200.303(a) requires recipients and subrecipients to establish, document, and mantain effective internal control over the federal award the provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: CRI notes the Organization did not consistently maintain documentation internal controls over the verification of vendor suspension and debarment status. Cause: the purchasing department did not consistently retain evidence of the process of verifying vendors suspension and debarment status. Effect: While there were no instances of noncompliance identified, the Organization could enter into transactions with vendors that are suspended or debarred. Recommendation: CRI recommends that the organization retain documentation of the verification of vendor suspension and debarment status prior to entering into covered transactions that are funded through federal programs. Response: See attached Corrective Action Plan.
ALN #93.788: Opioid State Targeted Response Pass through: Central Florida Behavioral Health Network, Lutheran Services, and Florida Alcohol and Drug Abuse Association Contract Number: QG034, ME056, DCF MOA Compliance Requirements: Suspension and Debarment Questioned Costs: N/A Criteria: 2 CFR 200.303(a) requires recipients and subrecipients to establish, document, and mantain effective internal control over the federal award the provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: CRI notes the Organization did not consistently maintain documentation internal controls over the verification of vendor suspension and debarment status. Cause: the purchasing department did not consistently retain evidence of the process of verifying vendors suspension and debarment status. Effect: While there were no instances of noncompliance identified, the Organization could enter into transactions with vendors that are suspended or debarred. Recommendation: CRI recommends that the organization retain documentation of the verification of vendor suspension and debarment status prior to entering into covered transactions that are funded through federal programs. Response: See attached Corrective Action Plan.
ALN #93.788: Opioid State Targeted Response Pass through: Central Florida Behavioral Health Network, Lutheran Services, and Florida Alcohol and Drug Abuse Association Contract Number: QG034, ME056, DCF MOA Compliance Requirements: Suspension and Debarment Questioned Costs: N/A Criteria: 2 CFR 200.303(a) requires recipients and subrecipients to establish, document, and mantain effective internal control over the federal award the provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: CRI notes the Organization did not consistently maintain documentation internal controls over the verification of vendor suspension and debarment status. Cause: the purchasing department did not consistently retain evidence of the process of verifying vendors suspension and debarment status. Effect: While there were no instances of noncompliance identified, the Organization could enter into transactions with vendors that are suspended or debarred. Recommendation: CRI recommends that the organization retain documentation of the verification of vendor suspension and debarment status prior to entering into covered transactions that are funded through federal programs. Response: See attached Corrective Action Plan.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 84.425, Department of Education, Education Stabilization Fund Federal Award Identification Number and Year: 213716 Pass-through Entity – Michigan Department of Education Finding Type – Material weakness in internal control over compliance Repeat Finding - No Criteria – Per 2 CFR § 200.303, The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – During our testing for Cash Management, it was noted that 1 out of 1 drawdown request selected for testing did not have evidence of review and approval. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – Management did not fully implement their internal control policies and procedures as there was no evidence of review and approvals, nor was documentation retained. Effect – Drawdown requests did not have evidence of review and approval. Recommendation – We recommend that management review its procedures and controls in place to ensure that reports and supporting documentation are retained and have proper evidence of review and approval. View of Responsible Officials and Corrective Action Plan – Management agrees with the finding. See corrective action plan.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 84.425, Department of Education, Education Stabilization Fund Federal Award Identification Number and Year: 213716 Pass-through Entity – Michigan Department of Education Finding Type – Material weakness in internal control over compliance Repeat Finding - No Criteria – Per 2 CFR § 200.303, The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – During our testing for Reporting, it was noted that 1 out of 1 report selected for testing did not have evidence of review and approval. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – Management did not fully implement their internal control policies and procedures as there was no evidence of review and approvals, nor was documentation retained. Effect – Reports did not have evidence of review and approval. Recommendation – We recommend that management review its procedures and controls in place to ensure that reports and supporting documentation are retained and have proper evidence of review and approval. View of Responsible Officials and Corrective Action Plan – Management agrees with the finding. See corrective action plan.