Finding Text
Department of Education, Passed through North Dakota Department of Public Instruction
Federal Financial Assistance Listing/CFDA Number 84.027/84.173
Special Education Cluster
Procurement, Suspension, and Debarment
Material Weakness in Internal Control over Compliance
Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards
non‐federal entities other than states must follow when operating federal programs and the procurement
procedures required.
Condition – In our testing of procurement, suspension and debarment it was identified that the District did not
have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through
200.326.
Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform
Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all
of these requirements.
Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific
requirements with contracting and awarding contracts to lower tier entities.
Questioned Costs – None reported
Context/Sampling – Overall procurement policy.
Repeat Finding from Prior Years – Yes, prior year finding 2022-004
Recommendation – We recommend that management establish a written policy that addresses all of the
procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and
maintain adequate supporting documentation and records to document history and methods of procurement
and the procedures performed to comply with these CFR sections.
Views of Responsible Officials – There is no disagreement with the audit finding.