Finding 1161933 (2024-006)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-11-05
Audit: 371829
Auditor: LB CARLSON

AI Summary

  • Core Issue: The District lacks effective internal controls to ensure compliance with federal suspension and debarment requirements for vendors in the child nutrition cluster.
  • Impacted Requirements: Compliance with 2 CFR § 180, which mandates checks against the federal Excluded Parties List for vendors exceeding $25,000.
  • Recommended Follow-Up: The District should enhance its internal control procedures and verify vendor eligibility to prevent future noncompliance.

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 10.555, 10.559, AND 10.553 2024-006 - Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 requires 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 the child nutrition cluster. Condition – During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster 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. Questioned Costs – None. Our testing did not indicate any instances of noncompliance with these requirements. Context – The District did not obtain the appropriate documentation for seven of seven vendors tested applicable to the child nutrition cluster to ensure the vendors were not suspended or debarred from participation in federal program contracts. This was not a statistically valid sample. Repeat Finding – This is a current and prior year finding. Cause – This was an oversight by district personnel. Effect – Noncompliance with the suspension and debarment requirements could result in the District 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 District review its internal control procedures relating to suspension and debarment for the child nutrition cluster federal programs. Internal controls over compliance for this area should include 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 for its 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.

Corrective Action Plan

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, AND 10.553 2024-006 - Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary Criteria – 2 CFR § 180 requires 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 the child nutrition cluster. Condition – The District did not have sufficient controls in place within its child nutrition cluster 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 District will review its 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 – Peter Olson-Skog, the District’s Superintendent. Planned Completion Date – December 31, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Peter Olson-Skog, the District’s Superintendent, will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

Categories

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

Other Findings in this Audit

  • 1161931 2024-006
    Material Weakness Repeat
  • 1161932 2024-006
    Material Weakness Repeat
  • 1161934 2024-007
    Material Weakness Repeat
  • 1161935 2024-007
    Material Weakness Repeat
  • 1161936 2024-007
    Material Weakness Repeat
  • 1161937 2024-007
    Material Weakness Repeat
  • 1161938 2024-007
    Material Weakness Repeat
  • 1161939 2024-007
    Material Weakness Repeat
  • 1161940 2024-007
    Material Weakness Repeat
  • 1161941 2024-007
    Material Weakness Repeat
  • 1161942 2024-007
    Material Weakness Repeat
  • 1161943 2024-007
    Material Weakness Repeat
  • 1161944 2024-007
    Material Weakness Repeat
  • 1161945 2024-007
    Material Weakness Repeat
  • 1161946 2024-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 NATIONAL SCHOOL LUNCH PROGRAM $1.91M
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.75M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $639,884
10.553 SCHOOL BREAKFAST PROGRAM $527,857
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $167,804
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $139,709
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $131,743
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $116,382
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $43,939
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $18,929
84.425 EDUCATION STABILIZATION FUND $4,642
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $1,465