Finding 517400 (2024-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-01-01

AI Summary

  • Core Issue: The District lacks formal documentation to verify vendor compliance with suspension and debarment requirements for the Child Nutrition Cluster.
  • Impacted Requirements: This finding violates 2 CFR §200.303, which mandates checks against the System for Award Management (SAM) for entities involved in covered transactions.
  • Recommended Follow-Up: The District should update its procurement policies to include documented controls ensuring all vendors are verified for suspension and debarment before transactions.

Finding Text

2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal 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 District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 517397 2024-004
    Material Weakness Repeat
  • 517398 2024-004
    Material Weakness Repeat
  • 517399 2024-004
    Material Weakness Repeat
  • 517401 2024-006
    Material Weakness
  • 517402 2024-006
    Material Weakness
  • 517403 2024-006
    Material Weakness
  • 517404 2024-006
    Material Weakness
  • 517405 2024-004
    Material Weakness Repeat
  • 517406 2024-004
    Material Weakness Repeat
  • 517407 2024-006
    Material Weakness
  • 517408 2024-006
    Material Weakness
  • 517409 2024-005
    Material Weakness Repeat
  • 517410 2024-007
    Material Weakness
  • 517411 2024-005
    Material Weakness Repeat
  • 517412 2024-007
    Material Weakness
  • 1093839 2024-004
    Material Weakness Repeat
  • 1093840 2024-004
    Material Weakness Repeat
  • 1093841 2024-004
    Material Weakness Repeat
  • 1093842 2024-004
    Material Weakness Repeat
  • 1093843 2024-006
    Material Weakness
  • 1093844 2024-006
    Material Weakness
  • 1093845 2024-006
    Material Weakness
  • 1093846 2024-006
    Material Weakness
  • 1093847 2024-004
    Material Weakness Repeat
  • 1093848 2024-004
    Material Weakness Repeat
  • 1093849 2024-006
    Material Weakness
  • 1093850 2024-006
    Material Weakness
  • 1093851 2024-005
    Material Weakness Repeat
  • 1093852 2024-007
    Material Weakness
  • 1093853 2024-005
    Material Weakness Repeat
  • 1093854 2024-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States $1.96M
10.553 School Breakfast Program $437,857
10.555 National School Lunch Program $298,323
84.010 Title I Grants to Local Educational Agencies $268,837
84.367 Improving Teacher Quality State Grants $179,813
84.365 English Language Acquisition State Grants $112,426
21.027 Coronavirus State and Local Fiscal Recovery Funds $72,022
32.009 Emergency Connectivity Fund Program $63,584
84.173 Special Education_preschool Grants $41,731
84.048 Career and Technical Education -- Basic Grants to States $13,502
10.558 Child and Adult Care Food Program $11,147
84.425 Education Stabilization Fund $10,122
84.060 Indian Education_grants to Local Educational Agencies $4,342
10.559 Summer Food Service Program for Children $186
10.556 Special Milk Program for Children $45