Finding 1229307 (2025-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-10
Audit: 410783
Auditor: LB CARLSON LLP

AI Summary

  • Core Issue: The District lacks adequate controls to ensure it does not contract with vendors who are suspended or debarred from federal program participation.
  • Impacted Requirements: Compliance with 2 CFR § 180 regarding suspension and debarment for federal program expenditures, specifically in the child nutrition cluster.
  • Recommended Follow-Up: The District should enhance its internal controls by verifying vendor eligibility against the federal Excluded Parties List for contracts over $25,000.

Finding Text

SIGNIFICANT DEFICIENCIES 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 2025-005 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 11 of 11 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 DEFICIENCIES 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 2025-005 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 – Brian Schultz, the District’s Finance Director. Planned Completion Date – December 31, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Brian Schultz, the District’s Finance Director, 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

Other Findings in this Audit

  • 1229305 2025-005
    Material Weakness Repeat
  • 1229306 2025-005
    Material Weakness Repeat
  • 1229308 2025-006
    Material Weakness Repeat
  • 1229309 2025-006
    Material Weakness Repeat
  • 1229310 2025-006
    Material Weakness Repeat
  • 1229311 2025-007
    Material Weakness Repeat
  • 1229312 2025-007
    Material Weakness Repeat
  • 1229313 2025-007
    Material Weakness Repeat
  • 1229314 2025-007
    Material Weakness Repeat
  • 1229315 2025-007
    Material Weakness Repeat
  • 1229316 2025-007
    Material Weakness Repeat
  • 1229317 2025-007
    Material Weakness Repeat
  • 1229318 2025-007
    Material Weakness Repeat
  • 1229319 2025-007
    Material Weakness Repeat
  • 1229320 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 NATIONAL SCHOOL LUNCH PROGRAM $1.77M
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.64M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $608,663
10.553 SCHOOL BREAKFAST PROGRAM $563,429
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $248,192
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $134,503
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $119,655
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $56,272
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $43,855
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $13,516