Finding 22821 (2022-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-01-24

AI Summary

  • Core Issue: The District lacks formal documentation to verify that vendors over $25,000 are not suspended or debarred before awarding contracts.
  • Impacted Requirements: Compliance with 2 CFR section 180.995 and related regulations for vendor verification is not being met.
  • Recommended Follow-Up: Review and update policies to ensure documentation of vendor checks is retained, using methods like SAM Exclusions or certifications.

Finding Text

FINDING: 2022-001 Type of Finding: Material weakness in internal control over and compliance with suspension and debarment Federal Agency: U.S. Department of Agriculture and U.S. Department of Treasury Federal Program Title: Child Nutrition Cluster and State and Local Fiscal Recovery Funds Assistance Listing Number: 10.553, 10.555, 10.559, and 21.027 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0077-000 Award Period: Year ended June 30, 2022 Criteria or Specific Requirement: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by: 1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA); 2) collecting a certification from the entity; or 3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The District did not retain formal documentation of its testing and controls to ensure that all vendors over the $25,000 contract threshold on a District-wide basis were not suspended or debarred prior to awarding the related contracts. Questioned Costs: None Context: None of the 8 contracts tested included formal documentation of the District?s testing and controls to ensure that all vendors over the $25,000 contract threshold on a District-wide basis were not suspended or debarred prior to awarding the related contracts. Cause: District has been unaware of formal documentation suspension and debarment requirements on a District-wide basis for any contract or procurement with all or part of the contract coded to the Food Service Fund. Effect: Lack of proper procedures and controls related to the suspension and debarment could result in improper contracts with suspended or debarred vendors being paid with federal funds. Repeat Finding: No Recommendation: We recommend that the District reviews its related policies and procedures to ensure it is retaining documentation showing that the District crosschecked the vendors with procurements over the threshold of $25,000 at the time of procurement, which could be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Minnesota Department of Education ISD #77 ? Mankato (the District) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement audit findings during fiscal year 2022. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS Finding 2022 ? 001 ? Child Nutrition Cluster ? Procurement Federal Agency: U.S. Department of Agriculture and U.S. Department of Treasury Federal Program Title: Child Nutrition Cluster and Local Fiscal Recovery Funds Assistance Listing Number: 10.553, 10.555, 10.559 and 21.027 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0077-000 Award Period: Year ended June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance with Suspension and Debarment Recommendation: We recommend that the District reviews its related policies and procedures to ensure it is retaining Documentation showing that the District crosschecked the vendors with procurements over the threshold of $25,000 at the time of procurement, which could be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2CFR section 180.300). Views of responsible officials and planned corrective actions: Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will implement the auditor recommendation to ensure it is retaining documentation showing that the District has controls over and is in compliance with procurement requirements. Responsible party: Darcy Stueber, Director of Food Services and Amanda Heilman, Director of Business Services. Planned completion date for corrective action plan: June 30, 2023. Plan to monitor completion of corrective action plan: The Board of Education and Superintendent will monitor the completion of this corrective action plan. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS (CONTINUED) Finding 2022 ? 001 ? State and Local Fiscal Recovery Funds ? Procurement Federal Agency: U.S. Department of the Treasury Federal Program Title: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: Minnesota Department of Treasury Pass-Through Number: not available Award Period: Year ended June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance Recommendation: It is recommended that the District creates some sort of standard procedure or form that indicates what method is being used to track all procured items over the micro-purchase threshold ($10,000) to help formally document of how open competition is being assessed and then retain documentation of any quotes, bids or direct negotiation procedures completed. Views of responsible officials and planned corrective actions: Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will implement the auditor recommendation to ensure it is retaining documentation showing that the District has controls over and is in compliance with procurement requirements. Responsible party: Darcy Stueber, Director of Food Services and Amanda Heilman, Director of Business Services. Planned completion date for corrective action plan: June 30, 2023. Plan to monitor completion of corrective action plan: The Board of Education and Superintendent will monitor the completion of this corrective action plan. FINDINGS?MINNESOTA LEGAL COMPLIANCE FINDINGS Recommendation: We recommend that the District implement controls to ensure that all bills are paid timely and are in compliance with state statutes. Views of responsible officials and planned corrective actions: Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will implement the auditor recommendation to ensure that bills are paid in accordance with timelines specified in state statutes. Responsible party: Amanda Heilman, Director of Business Services. Planned completion date for corrective action plan: June 30, 2023. Plan to monitor completion of corrective action plan: The Board of Education and Superintendent will monitor the completion of this corrective action plan. If the Minnesota Department of Education has questions regarding this plan, please call Amanda Heilman, Director of Business Services, at 507-387-3167.

Categories

Procurement, Suspension & Debarment School Nutrition Programs

Other Findings in this Audit

  • 22822 2022-001
    Material Weakness
  • 22823 2022-001
    Material Weakness
  • 22824 2022-001
    Material Weakness
  • 22825 2022-001
    Material Weakness
  • 22826 2022-001
    Material Weakness
  • 22827 2022-001
    Material Weakness
  • 22828 2022-002
    Material Weakness
  • 22829 2022-001
    Material Weakness
  • 22830 2022-002
    Material Weakness
  • 22831 2022-001
    Material Weakness
  • 22832 2022-002
    Material Weakness
  • 22833 2022-001
    Material Weakness
  • 22834 2022-002
    Material Weakness
  • 22835 2022-001
    Material Weakness
  • 22836 2022-002
    Material Weakness
  • 22837 2022-001
    Material Weakness
  • 22838 2022-002
    Material Weakness
  • 599263 2022-001
    Material Weakness
  • 599264 2022-001
    Material Weakness
  • 599265 2022-001
    Material Weakness
  • 599266 2022-001
    Material Weakness
  • 599267 2022-001
    Material Weakness
  • 599268 2022-001
    Material Weakness
  • 599269 2022-001
    Material Weakness
  • 599270 2022-002
    Material Weakness
  • 599271 2022-001
    Material Weakness
  • 599272 2022-002
    Material Weakness
  • 599273 2022-001
    Material Weakness
  • 599274 2022-002
    Material Weakness
  • 599275 2022-001
    Material Weakness
  • 599276 2022-002
    Material Weakness
  • 599277 2022-001
    Material Weakness
  • 599278 2022-002
    Material Weakness
  • 599279 2022-001
    Material Weakness
  • 599280 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies $1.35M
10.553 School Breakfast Program $957,840
10.559 Summer Food Service Program for Children $479,740
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $450,570
84.367 Improving Teacher Quality State Grants $201,476
10.555 National School Lunch Program $143,413
84.002 Adult Education - Basic Grants to States $99,961
84.173 Special Education_preschool Grants $76,809
84.181 Special Education-Grants for Infants and Families $68,308
84.365 English Language Acquisition State Grants $63,030
21.027 Coronavirus State and Local Fiscal Recovery Funds $46,348
84.048 Career and Technical Education -- Basic Grants to States $22,705
84.425 Education Stabilization Fund $8,856
84.196 Education for Homeless Children and Youth $8,003
10.649 Pandemic Ebt Administrative Costs $5,270
84.027 Special Education_grants to States $3,538
10.558 Child and Adult Care Food Program $1,116