Finding 513654 (2024-002)

Significant Deficiency
Requirement
I
Questioned Costs
$1
Year
2024
Accepted
2024-12-09

AI Summary

  • Core Issue: The District lacks effective internal controls over compliance with federal procurement requirements, leading to instances of noncompliance.
  • Impacted Requirements: Failure to obtain two or more quotations for contracts over $10,000 violates 2CFR § 200.320 and Uniform Guidance.
  • Recommended Follow-Up: Review and strengthen procurement procedures to ensure consistent application of controls, including obtaining required quotations and maintaining proper documentation.

Finding Text

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORETABLE INSTANCES OF NONCOMPLIANCE– U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-002 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Criteria – 2CFR § 200.320 requires the District to establish and maintain effective internal control over compliance with procurement requirements applicable to expenditures within its special education cluster federal programs. Condition – Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in reportable instances of noncompliance. Questioned Costs – $92,850. Context – For two of six vendors tested, the District did not obtain two or more quotations for contracts awarded in excess of its stated micro-purchase threshold of $10,000 within its special education cluster federal programs, as required by the Uniform Guidance. All contracts required to be awarded based on multiple quotations within the District’s special education cluster federal programs were tested. Repeat Finding – This is a current year finding. Cause – The District’s internal control procedures over procurement requirements applicable to its special education cluster federal programs were not being consistently followed. Effect – Noncompliance with the procurement requirements could result in the District expending federal funds inappropriately or not obtaining competitively prices goods or services, which could be viewed as a violation of the award agreement. Recommendation – We recommend the District review its internal control procedures for its special education cluster federal programs to ensure that controls in place over compliance with federal procurement requirements are being consistently applied, including awarding contracts based on multiple quotations for the purchase of goods or services in excess of the District’s micro-purchase threshold of $10,000, as required by the Uniform Guidance. View of Responsible Official and Planned Corrective Actions – There is no disagreement with the audit finding. District management will review its procedures relating to procurement for its federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. The District has separately issued a Corrective Action Plan related to this finding.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 513650 2024-001
    Significant Deficiency
  • 513651 2024-001
    Significant Deficiency
  • 513652 2024-001
    Significant Deficiency
  • 513653 2024-002
    Significant Deficiency
  • 513655 2024-002
    Significant Deficiency
  • 1090092 2024-001
    Significant Deficiency
  • 1090093 2024-001
    Significant Deficiency
  • 1090094 2024-001
    Significant Deficiency
  • 1090095 2024-002
    Significant Deficiency
  • 1090096 2024-002
    Significant Deficiency
  • 1090097 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $3.43M
10.553 School Breakfast Program $582,506
84.010 Title I Grants to Local Educational Agencies $341,999
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $206,386
84.048 Career and Technical Education -- Basic Grants to States $124,700
84.181 Special Education-Grants for Infants and Families $95,728
84.027 Special Education Grants to States $91,372
84.173 Special Education Preschool Grants $58,836
84.365 English Language Acquisition State Grants $57,028
84.060 Indian Education Grants to Local Educational Agencies $29,704
84.424 Student Support and Academic Enrichment Program $22,810
10.649 Pandemic Ebt Administrative Costs $3,256
21.027 Coronavirus State and Local Fiscal Recovery Funds $2,635
84.425 Education Stabilization Fund $1,972