FAC Explorer

Finding 504638 (2023-007)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-11-04
Audit: 327202
Organization: Saint Paul Public Schools (MN)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The School District failed to verify compliance with suspension and debarment requirements for all covered transactions in FY 2023.
  • Impacted Requirements: The District did not follow the Uniform Guidance, which mandates verification of entities involved in covered transactions to ensure they are not suspended or debarred.
  • Recommended Follow-Up: The District should formalize its suspension and debarment procedures in a written policy and review controls to ensure proper verification for all transactions.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) 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 Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) 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 2 out of 2 covered transactions in fiscal year 2023. Context: Both of the covered transactions which were tested did not have documentation that the District performed the required verifications. Questioned Costs: None Cause: The District 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 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. Additionally, it is recommended the District formalize its procedures in a written policy. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Material Weakness in Internal Control Over Compliance and Material Noncompliance Suspension and Debarment 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. Additionally, it is recommended the District formalize its procedures in a written policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will review its procedures over federal procurements to incorporate controls to ensure suspension and debarment procedures are performed over all new contracts. Name(s) of the contact person(s) responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2024

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 504618 2023-004
    Material Weakness
  • 504619 2023-004
    Material Weakness
  • 504620 2023-004
    Material Weakness
  • 504621 2023-004
    Material Weakness
  • 504622 2023-005
    Material Weakness
  • 504623 2023-005
    Material Weakness
  • 504624 2023-005
    Material Weakness
  • 504625 2023-005
    Material Weakness
  • 504626 2023-008
    Material Weakness Repeat
  • 504627 2023-008
    Material Weakness Repeat
  • 504628 2023-008
    Material Weakness Repeat
  • 504629 2023-008
    Material Weakness Repeat
  • 504630 2023-003
    Material Weakness Repeat
  • 504631 2023-003
    Material Weakness Repeat
  • 504632 2023-003
    Material Weakness Repeat
  • 504633 2023-003
    Material Weakness Repeat
  • 504634 2023-006
    Material Weakness Repeat
  • 504635 2023-006
    Material Weakness Repeat
  • 504636 2023-006
    Material Weakness Repeat
  • 504637 2023-006
    Material Weakness Repeat
  • 504639 2023-007
    Material Weakness Repeat
  • 504640 2023-007
    Material Weakness Repeat
  • 504641 2023-007
    Material Weakness Repeat
  • 504642 2023-009
    Significant Deficiency
  • 504643 2023-009
    Significant Deficiency
  • 504644 2023-009
    Significant Deficiency
  • 504645 2023-009
    Significant Deficiency
  • 1081060 2023-004
    Material Weakness
  • 1081061 2023-004
    Material Weakness
  • 1081062 2023-004
    Material Weakness
  • 1081063 2023-004
    Material Weakness
  • 1081064 2023-005
    Material Weakness
  • 1081065 2023-005
    Material Weakness
  • 1081066 2023-005
    Material Weakness
  • 1081067 2023-005
    Material Weakness
  • 1081068 2023-008
    Material Weakness Repeat
  • 1081069 2023-008
    Material Weakness Repeat
  • 1081070 2023-008
    Material Weakness Repeat
  • 1081071 2023-008
    Material Weakness Repeat
  • 1081072 2023-003
    Material Weakness Repeat
  • 1081073 2023-003
    Material Weakness Repeat
  • 1081074 2023-003
    Material Weakness Repeat
  • 1081075 2023-003
    Material Weakness Repeat
  • 1081076 2023-006
    Material Weakness Repeat
  • 1081077 2023-006
    Material Weakness Repeat
  • 1081078 2023-006
    Material Weakness Repeat
  • 1081079 2023-006
    Material Weakness Repeat
  • 1081080 2023-007
    Material Weakness Repeat
  • 1081081 2023-007
    Material Weakness Repeat
  • 1081082 2023-007
    Material Weakness Repeat
  • 1081083 2023-007
    Material Weakness Repeat
  • 1081084 2023-009
    Significant Deficiency
  • 1081085 2023-009
    Significant Deficiency
  • 1081086 2023-009
    Significant Deficiency
  • 1081087 2023-009
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies $28.98M
10.555 National School Lunch Program $12.36M
10.553 School Breakfast Program $4.98M
84.424 Student Support and Academic Enrichment Program $2.47M
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $2.44M
84.365 English Language Acquisition State Grants $1.74M
84.002 Adult Education - Basic Grants to States $1.50M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.43M
84.287 Twenty-First Century Community Learning Centers $1.39M
84.371 Comprehensive Literacy Development $1.10M
10.559 Summer Food Service Program for Children $850,546
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $800,470
84.048 Career and Technical Education -- Basic Grants to States $780,871
10.558 Child and Adult Care Food Program $769,347
84.027 Special Education Grants to States $720,395
84.411 Education Innovation and Research (formerly Investing in Innovation (i3) Fund) $688,959
32.009 Emergency Connectivity Fund Program $480,000
12.U01 Rotc $431,136
10.582 Fresh Fruit and Vegetable Program $428,949
84.336 Teacher Quality Partnership Grants $334,099
84.415 Indian Education National Activities (state Tribal Education Partnership (step) and Native American Language (nal) $188,539
84.060 Indian Education Grants to Local Educational Agencies $174,402
84.173 Special Education Preschool Grants $157,815
84.305 Education Research, Development and Dissemination $154,253
93.959 Block Grants for Prevention and Treatment of Substance Abuse $148,500
20.205 Highway Planning and Construction $118,149
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $87,912
84.196 Education for Homeless Children and Youth $82,140
16.839 Stop School Violence $74,009
84.181 Special Education-Grants for Infants and Families $71,055
84.425 Education Stabilization Fund $57,853
10.185 Local Food for Schools Cooperative Agreement Program $21,568
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $20,400
10.649 Pandemic Ebt Administrative Costs $6,180
10.226 Secondary Education, Two-Year Postsecondary Education, and Agriculture in the K-12 Classroom $4,513
93.297 Teenage Pregnancy Prevention Program $835