Finding 561667 (2024-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-05-28
Audit: 357302
Organization: Aurora Charter School (MN)
Auditor: Lb Carlson

AI Summary

  • Core Issue: The School lacks effective internal controls to ensure compliance with federal suspension and debarment requirements for its Comprehensive Literacy Development program.
  • Impacted Requirements: Noncompliance with 2 CFR § 180 and 2 CFR § 200.318-327, which mandates proper procurement practices to avoid contracting with suspended or debarred parties.
  • Recommended Follow-Up: The School should enhance its internal control procedures, ensuring proper documentation and verification against the federal Excluded Parties List for vendors exceeding $25,000.

Finding Text

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COMPREHENSIVE LITERACY DEVELOPMENT, FEDERAL ALN 84.371 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria – 2 CFR § 180 and 2 CFR § 200.318-327 requires that Aurora Charter School (the School) to establish and maintain effective internal control over compliance with requirements appliable to federal program expenditures, including suspension and drebarment requirements applicable to the Comprehensive Literacy Development federal program. Condition – During our audit, we noted the School did not have sufficient controls in place within its comprehensive literacy development federal program to ensure compliance with federal procurement requirements related to suspension and debarment and that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Context – For one of one vendors exceeding the federal threshold of $25,000, the School did not document its compliance with procurement policies over suspension and debarment and documentation of compliance with suspension and debarment requirements was not maintained for one of one vendors tested to ensure compliance with this requirement in the current year. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – This was an oversight by school personnel. Effect – Noncompliance with suspension and debarment requirements could result in the School expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the School review its internal control procedures relating to suspension and debarment for the Comprehensive Literacy Development federal program. Internal controls over compliance for this area should include documentation of procurement policies over suspension and debarment. These controls should also include steps to ensure any vendor with which the School contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The School agrees with the finding. The School will review and update its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The School has separately issued a Corrective Action Plan related to this finding.

Corrective Action Plan

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COMPREHENSIVE LITERACY DEVELOPMENT, FEDERAL ALN 84.371 2024-001 Internal Control Over Compliance With Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires Aurora Charter School (the School) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the comprehensive literacy development federal program. During our audit, we noted the School did not have sufficient controls in place within its Comprehensive Literacy Development federal program to ensure compliance with federal procurement requirements related to suspension and debarment and to assure that it was not contracting for goods or services with parties that are suspendded or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The School has updated its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The updated procedures include steps so that School personnel are following the requirements of the Uniform Guidance related to suspension and debarment requirements including maininging appropriate documentation. Official Responsible – The School's Executive Director, Matthew Cisewski. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The School agrees with this finding. Plan to Monitor – The School’s Executive Director, Matthew Cisewski, will monitor the updating of policies and procedures related to suspension and debarment to ensure these requirements are complied with in the future.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.371 Comprehensive Literacy Development $528,217
84.425 Education Stabilization Fund $277,239
10.555 National School Lunch Program $253,988
84.010 Title I Grants to Local Educational Agencies $221,715
84.027 Special Education Grants to States $171,984
10.553 School Breakfast Program $61,081
84.365 English Language Acquisition State Grants $42,440
10.559 Summer Food Service Program for Children $15,342
84.173 Special Education Preschool Grants $2,625