Finding Text
Finding 2022-003 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, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR ? 180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District 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. Condition: In our testing for the Special Education Cluster, we noted instances where there was no documentation of this verification being performed. Questioned Costs: None Context: During testing of the program, it was noted that five of seven contacts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government. Cause: The District?s practice of ensuring sam.gov was checked for all contracts entered into and documentation retained was not performed as expected during the pandemic, and shortly thereafter during fiscal year 2022. Effect: The District was not in compliance with federal suspension and debarment requirements. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-010 in the previous report for fiscal year 2021. Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained. Views of responsible officials: There is no disagreement with the audit finding.