Finding Text
2025-003: Material Weakness in Internal Controls over Compliance with Suspension and Debarment Federal Assistance Listing Number: 10.553, 10.555, and 10.582 Federal Award Year: 2025 Program Title: Child Nutrition Cluster Name of Federal Agency: U.S. Department of Agriculture Name of Pass-Through Entity: Colorado Department of Education COVID-19 Program: No Criteria: 2 CFR §200.303 requires that the grant recipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control- Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Based on our sample selection of three vendors for testing, we have identified that two of the three vendors tested did not have adequate verification of suspension and debarment. Upon further testing and discussion, the District does not have internal controls in place to verify suspension and debarment on vendors that are paid greater than or equal to $25,000, as required by 2 CFR 200 for various federal awards. Upon further compliance testing, vendors in our testing were in compliance with the requirement. Without internal controls over compliance, the District may not be able to identify noncompliance with a suspended or debarred vendors in a timely manner and may incur potential questioned costs without knowledge of the noncompliance. Questioned Costs: No questioned costs have been identified. Cause: The District’s internal controls over suspension and debarment requirement were not properly designed or implemented. Effect: Without internal controls over compliance, the District may not be able to identify noncompliance with a suspended or debarred vendors in a timely manner and may incur potential questioned costs without knowledge of the noncompliance. Repeat Finding: No. Recommendation: We recommend that the District implement internal controls over the suspension and debarment requirement and add this requirement to the procurement process at the District. In addition, we recommend that the District periodically review federal expenditure reports to identify vendors that may have been paid with federal grants in excess of the $25,000 suspension and debarment threshold to prevent potential noncompliance. Corrective Action Plan: Reported on page 60.