Finding 1138035 (2024-003)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-05-27
Audit: 357218
Auditor: Lb Carlson

AI Summary

  • Core Issue: The Academy lacks effective internal controls to ensure compliance with federal suspension and debarment requirements for vendors in the child nutrition program.
  • Impacted Requirements: Compliance with 2 CFR § 180 and 2 CFR § 200.318-327 is necessary to avoid contracting with suspended or debarred parties.
  • Recommended Follow-Up: The Academy should enhance its internal controls and maintain proper documentation to verify vendor eligibility, particularly for contracts exceeding $25,000.

Finding Text

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – (FEDERAL ALN 10.553 AND 10.555) 2024-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 and 2 CFR § 200.318-327 requires Universal Academy (the Academy) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal program. Condition – During our audit, we noted the Academy did not have sufficient controls in place within its child nutrition cluster federal program to ensure 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 – Not applicable. Context – For two of two vendors exceeding the federal threshold of $25,000, proper documentation of suspension and debarment testing was not maintained to ensure compliance with this requirement. This was not a statistically valid sample. Repeat Finding – This is a current and prior year finding. Cause – This was an oversight by academy personnel. Effect – Noncompliance with suspension and debarment requirements could result in the Academy 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 Academy review its internal control procedures relating to suspension and debarment for the child nutrition cluster federal program. Internal controls over compliance in this area should include documentation of procurement policies and the Uniform Guidance requirements related to suspension and debarment. These controls should also include steps to ensure any vendor with which the Academy 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 Academy agrees with the finding. The Academy will review and update its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The Academy has separately issued a Corrective Action Plan related to this finding.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 561593 2024-003
    Significant Deficiency Repeat
  • 561594 2024-003
    Significant Deficiency Repeat
  • 561595 2024-004
    Significant Deficiency
  • 561596 2024-004
    Significant Deficiency
  • 561597 2024-005
    Significant Deficiency
  • 561598 2024-006
    Significant Deficiency Repeat
  • 561599 2024-007
    - Repeat
  • 561600 2024-007
    - Repeat
  • 561601 2024-007
    - Repeat
  • 561602 2024-007
    - Repeat
  • 561603 2024-007
    - Repeat
  • 561604 2024-007
    - Repeat
  • 561605 2024-007
    - Repeat
  • 561606 2024-007
    - Repeat
  • 1138036 2024-003
    Significant Deficiency Repeat
  • 1138037 2024-004
    Significant Deficiency
  • 1138038 2024-004
    Significant Deficiency
  • 1138039 2024-005
    Significant Deficiency
  • 1138040 2024-006
    Significant Deficiency Repeat
  • 1138041 2024-007
    - Repeat
  • 1138042 2024-007
    - Repeat
  • 1138043 2024-007
    - Repeat
  • 1138044 2024-007
    - Repeat
  • 1138045 2024-007
    - Repeat
  • 1138046 2024-007
    - Repeat
  • 1138047 2024-007
    - Repeat
  • 1138048 2024-007
    - Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $337,909
84.010 Title I Grants to Local Educational Agencies $175,704
10.553 School Breakfast Program $137,155
84.027 Special Education Grants to States $117,607
84.425 Education Stabilization Fund $89,876
84.365 English Language Acquisition State Grants $37,002
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $23,593
84.424 Student Support and Academic Enrichment Program $15,701