Finding 58463 (2022-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-02-21

AI Summary

  • Core Issue: The District lacks adequate controls to ensure compliance with federal suspension and debarment requirements for vendors under the coronavirus recovery funds.
  • Impacted Requirements: 2 CFR 180 mandates effective internal controls to prevent contracting with suspended or debarred parties.
  • Recommended Follow-Up: The District should enhance its internal controls by verifying vendor eligibility against the federal Excluded Parties List for contracts over $25,000.

Finding Text

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS ? FEDERAL ALN 21.027 2022-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria ? 2 CFR ? 180 requires Independent School District No. 833 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the coronavirus state and local fiscal recovery funds federal program. Condition ? During our audit, we noted the District did not have sufficient controls in place within its coronavirus state and local fiscal recovery funds federal program to assure 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. Our testing did not indicate any instances of noncompliance with these requirements. Context ? The District did not obtain the appropriate documentation for one of two vendors tested applicable to the coronavirus state and local fiscal recovery funds to ensure the vendor was not suspended or debarred from participation in federal program contracts. Repeat Finding ? This is a current year finding. Cause ? This was an oversight by district personnel. Effect ? Noncompliance with the suspension and debarment requirements could result in the District expending federal funds with 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 District review its internal control procedures relating to suspension and debarment for the coronavirus state and local fiscal recovery funds federal program. Internal controls over compliance for this area should include verification that any vendor with which the District 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 District agrees with the finding. The District 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 District has separately issued a Corrective Action Plan related to this finding.

Corrective Action Plan

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS ? FEDERAL ALN 21.027 2022-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR ? 180 requires Independent School District No. 833 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the coronavirus state and local fiscal recovery funds federal program. The District did not have sufficient controls in place within its coronavirus state and local fiscal recovery funds federal program to assure 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. Corrective Action Plan Actions Planned ? The District will review policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible ? Kris Blackburn, Fiscal Services Director. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The District is in agreement with this finding. Plan to Monitor ? The District?s Fiscal Services Director will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Significant Deficiency

Other Findings in this Audit

  • 58464 2022-003
    Significant Deficiency
  • 634905 2022-002
    Significant Deficiency
  • 634906 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $8.71M
10.553 School Breakfast Program $1.67M
32.009 Emergency Connectivity Fund Program $751,843
21.027 Coronavirus State and Local Fiscal Recovery Funds $650,022
84.010 Title I Grants to Local Educational Agencies $470,310
93.575 Child Care and Development Block Grant $245,200
84.181 Special Education-Grants for Infants and Families $240,210
10.559 Summer Food Service Program for Children $230,965
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $221,589
84.367 Supporting Effective Instruction State Grants $211,312
84.027 Special Education_grants to States $189,847
84.365 English Language Acquisition State Grants $94,562
84.002 Adult Education - Basic Grants to States $70,088
84.424 Student Support and Academic Enrichment Program $40,261
84.048 Career and Technical Education -- Basic Grants to States $37,146
84.060 Indian Education_grants to Local Educational Agencies $24,793
84.173 Special Education_preschool Grants $19,467
84.425 Education Stabilization Fund $12,443
84.196 Education for Homeless Children and Youth $2,631