Finding Text
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173
2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements
Criteria – 2 CFR § 180 requires Independent School District No. 728 (the District) to
establish and maintain effective internal control over compliance with requirements
applicable to federal program expenditures, including suspension and debarment
requirements applicable to child nutrition cluster federal programs.
Condition – Our testing indicated that the District did not have sufficient controls in place
within its special education cluster federal programs to assure it was not contracting for goods
or services with parties that are suspended or debarred, or whose principals are suspended or
debarred from participating in contracts involving the expenditures of federal program funds.
Questioned Costs – None. Our testing did not indicate any instances of noncompliance with this requirement.
Context – The District has properly designed internal controls in place over suspension and
debarment requirements applicable to special education cluster federal programs. However,
for three of three contracts tested, the District did not retain adequate documentation that
these procedures had been performed. This was not a statistically valid sample.
Repeat Finding – This is a current year finding.
Cause – The District did not retain adequate documentation that it had verified the vendors
with which the District contracted for goods or services exceeding $25,000 during the year
within its special education cluster federal programs were not suspended or debarred.
Effect – Noncompliance with the procurement requirements could result in the District
expending federal funds inappropriately or utilizing vendors that are not eligible to be parties
to such transactions, which could be viewed as a violation of the award agreement.
Recommendation – We recommend that the District review its internal control procedures
relating to suspension and debarment applicable to special education cluster federal
programs. Internal controls over compliance for this area should include adequate
documentation of verification that any vendor with which the District contracts for goods or
services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded
Parties List System website.
View of Responsible Official and Planned Corrective Actions – The District agrees with the finding.
The District will review and update its policies and procedures relating to suspension and debarment
applicable to special education cluster federal programs to ensure compliance with the Uniform Guidance
in the future. The District has separately issued a Corrective Action Plan related to this finding.