Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Special Education Cluster
Assistance Listing Number: 84.027, and 84.173
Federal Award Identification Number and Year: H027A210087 and H173A180086
Pass-Through Agency: Minnesota Department of Education
Pass-Through Numbers: Unknown
Award Period: Fiscal Year 2023
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
Criteria: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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 two covered transactions in fiscal year 2023.
Context: Of two covered transactions tested in the Special Education Cluster, it was noted that the District did not perform the required verifications on either of the two covered transactions.
Questioned Costs: None
Cause: The District has had turnover in some roles within the Special Education program.
Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it.
Repeat Finding: Yes – 2022-003
Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds.
View of Responsible
Official: There is no disagreement with the audit finding.