Finding 10812 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-01-30

AI Summary

  • Core Issue: The Cooperative lacks adequate controls to ensure compliance with federal suspension and debarment requirements for vendors in special education programs.
  • Impacted Requirements: Noncompliance with 2 CFR § 180 and 2 CFR § 200 could lead to using ineligible vendors for federal fund expenditures.
  • Recommended Follow-Up: The Cooperative should review and update its policies on suspension and debarment to align with Uniform Guidance requirements.

Finding Text

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 2023-001 Internal Control Over Compliance with Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 and 2 CFR § 200 requires the Cooperative to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the special education cluster federal programs. Condition – During our audit, we noted that the Cooperative did not have sufficient controls in place within the special education cluster federal programs to assure compliance with contracting for goods and services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – Not applicable. Context – The Cooperative did not obtain appropriate documentation for one of one vendors tested. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – This was an oversight by district personnel. Effect – Noncompliance with the suspension and debarment requirements could result in the Cooperative expending federal funds with vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the Cooperative review their procedures relating to suspension and debarment requirements to ensure they are in compliance with Uniform Guidance requirements. View of Responsible Official and Planned Corrective Actions – The Cooperative agrees with the finding. The Cooperative will review and update its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance requirements. The Cooperative has separately issued a Corrective Action Plan related to this finding.

Corrective Action Plan

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 2023-001 Internal Control Over Compliance with Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and CFR § 200 requires the Cooperative to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements. The Cooperative did not have sufficient controls in place within its special education cluster federal programs to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The Cooperative will review policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – Tracy Wells, Business Manager. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Tracy Wells, Business Manager, will assure appropriate controls are in place, and will review internal control procedures relating to suspension and debarment to ensure they are in line with the Uniform Guidance requirements.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Significant Deficiency

Other Findings in this Audit

  • 10813 2023-001
    Significant Deficiency
  • 10814 2023-001
    Significant Deficiency
  • 587254 2023-001
    Significant Deficiency
  • 587255 2023-001
    Significant Deficiency
  • 587256 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States $244,910
84.425 Education Stabilization Fund $155,274
21.027 Coronavirus State and Local Fiscal Recovery Funds $99,311
84.173 Special Education_preschool Grants $50,401
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $30,085
84.181 Special Education-Grants for Infants and Families $3,805