Finding Text
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER ? FEDERAL ALN 10.553, 10.555, AND 10.559 2022-002 Internal Control Over Compliance With Suspension and Debarment Requirements Criteria ? 2 CFR ? 180 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to its child nutrition cluster federal programs. Condition ? During our audit, we noted the Academy did not have sufficient controls in place within its child nutrition cluster federal programs to ensure 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, as required by Uniform Guidance. For the three vendors tested, the Academy did not have documentation of performing vendor checks for suspension and debarment. Questioned Costs ? None. Context ? The Academy did not have documentation of performing vendor checks for the three vendors tested to ensure the vendor was not suspended or debarred from participation in federal program contracts. This was not a statistically valid sample. Repeat Finding ? This is a current year and prior year finding. Cause ? This was an oversight by academy personnel. Effect ? Noncompliance with suspension and debarment requirements could result in the Academy contracting with vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. However, based on our testing, no reportable instances of noncompliance were noted in this area. Recommendation ? We recommend that the Academy review its internal controls over suspension and debarment to ensure they include adequate controls and include required verification that any vendor with which the Academy contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. Further, all individuals with oversight of federal program expenditures should have a sufficient understanding of federal suspension and debarment. View of Responsible Official and Planned Corrective Actions ? The Academy agrees with the finding. The Academy will review its procedures relating to suspension and debarment for its federal programs, and ensure all individuals with oversight of federal program expenditures have a sufficient understanding of these requirements. The Academy has separately issued a Corrective Action Plan related to this finding.