Finding 1176583 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-05
Audit: 390389
Auditor: LB CARLSON LLP

AI Summary

  • Core Issue: The District lacks effective internal controls over compliance with federal procurement requirements for its child nutrition programs, leading to a reportable instance of noncompliance.
  • Impacted Requirements: The District failed to obtain required quotations for contracts exceeding the micro-purchase threshold of $10,000, violating 2 CFR § 200.320.
  • Recommended Follow-Up: The District should enhance its procurement procedures to ensure consistent application of controls, including obtaining multiple quotations and maintaining proper documentation.

Finding Text

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCE OF NONCOMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.582 2025-002 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Criteria – 2 CFR § 200.320 requires the District to establish and maintain effective internal control over compliance with procurement requirements applicable to expenditures within its child nutrition cluster federal programs. Condition – During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in a reportable instance of noncompliance. Questioned Costs – $28,450. Context – For one of twenty-five vendors tested, the District could not provide documentation that two or more quotations were solicited for a contract awarded within its child nutrition cluster federal programs in excess of its stated micro-purchase threshold of $10,000, as required by the Uniform Guidance. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – The District’s internal control procedures over procurement requirements applicable to its child nutrition cluster federal programs were not being consistently followed. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or not obtaining competitively priced goods or services, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures for its child nutrition cluster federal programs to ensure that controls in place over compliance with federal procurement requirements are being consistently applied, including awarding contracts based on multiple quotations for the purchase of goods or services in excess of the District’s micro-purchase threshold of $10,000, as required by the Uniform Guidance. View of Responsible Official and Planned Corrective Actions – There is no disagreement with the audit finding. District management will review its procedures relating to procurement for its federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. The District solicited quotes and retained the necessary documentation for the noncompliant contract in fiscal year 2026. The District has separately issued a Corrective Action Plan related to this finding.

Corrective Action Plan

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCE OF NONCOMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.582 2025-002 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Finding Summary 2 CFR § 200.320 requires Independent School District No. 280 (the District) to establish and maintain effective internal control over compliance with requirements applicable to its federal program expenditures, including applicable procurement requirements. The District did not have sufficient controls in place within the child nutrition cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in reportable a instance of noncompliance. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to procurement for its child nutrition cluster federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. The District solicited quotes and retained the necessary documentation for the noncompliant contract in fiscal year 2026. Official Responsible – The District’s Director of Finance, Heidi Savatdy. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Chief Administrative Officer, Craig Holje, will monitor the implementation of these corrective actions as implemented by the Director of Finance to ensure appropriate controls over federal procurement requirements are in place and being consistently applied to ensure multiple quotations are solicited and retained for contracts awarded for goods or services in excess of the District’s micro-purchase threshold, as required by the Uniform Guidance.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1176581 2025-002
    Material Weakness Repeat
  • 1176582 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 NATIONAL SCHOOL LUNCH PROGRAM $1.60M
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.02M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $855,595
10.553 SCHOOL BREAKFAST PROGRAM $595,156
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $138,943
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $136,042
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $132,714
10.558 CHILD AND ADULT CARE FOOD PROGRAM $83,229
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $73,379
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $51,740
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $48,383
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $46,271
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $15,743
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $14,658
84.425 EDUCATION STABILIZATION FUND $670