Finding Text
Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: The district should have controls in place to ensure compliance with suspension and debarment requirements. The Uniform Guidance requires that 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 either checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause to the covered transaction with the entity. Condition: The School District did not perform the required verification procedures over a covered transaction in fiscal year 2022. Context: Out of five covered transactions which were tested, we noted that one of them did not have documentation that the District performed the required verifications. Questioned Costs: None Cause: The district was unaware that they needed documentation for noncompetitive covered transactions as well as their policy did not formalize the District?s suspension and debarment procedures. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over suspension and debarment to ensure that all covered transactions are properly verified to not be suspended or debarred such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.