Finding Text
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COMPREHENSIVE LITERACY DEVELOPMENT, FEDERAL ALN 84.371
2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements
Criteria – 2 CFR § 180 and 2 CFR § 200.318-327 requires that Aurora Charter School (the School) to establish and maintain effective internal control over compliance with requirements appliable to federal program expenditures, including suspension and drebarment requirements applicable to the Comprehensive Literacy Development federal program.
Condition – During our audit, we noted the School did not have sufficient controls in place within its comprehensive literacy development federal program to ensure compliance with federal procurement requirements related to suspension and debarment and 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.
Questioned Costs – None.
Context – For one of one vendors exceeding the federal threshold of $25,000, the School did not document its compliance with procurement policies over suspension and debarment and documentation of compliance with suspension and debarment requirements was not maintained for one of one vendors tested to ensure compliance with this requirement in the current year. This was not a statistically valid sample.
Repeat Finding – This is a current year finding.
Cause – This was an oversight by school personnel.
Effect – Noncompliance with suspension and debarment requirements could result in the School 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 School review its internal control procedures relating to suspension and debarment for the Comprehensive Literacy Development federal program. Internal controls over compliance for this area should include documentation of procurement policies over suspension and debarment. These controls should also include steps to ensure any vendor with which the School 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 School agrees with the finding. The School 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 School has separately issued a Corrective Action Plan related to this finding.