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.