Finding Text
Federal agency: U.S. Department of Education
Federal program name: Special Education Cluster
Assistance Listing Number: 84.027 and 84.173
Federal Award Identification Number and Year: H027A220087, 2023
Pass-Through Agency: Minnesota Department of Education
Pass-Through Number: H027A190087
Award Period: Fiscal year 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. 2 CFR 200.303 requires that the entity have sufficient controls over compliance related to federal awards.
Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented.
Questioned Costs: ALN 84.027 - $38,869
Context: Out of five procurement which were tested, we noted two of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor.
Cause: The District during the pandemic and thereafter, was not able to properly ensure all contracts has procurement documentation retained and performed as required by the Uniform Guidance.
Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes, 2022-004.
Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented 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.