Finding Text
Federal Agencies: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria: The district should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster. The Uniform Guidance requires that when a non-federal 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 School District did not perform the required verification procedures over covered transactions in the child nutrition program in fiscal year 2022. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on any of the five. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Cause: The District has had turnover in some roles within the Child Nutrition program and not all of the program requirements were known to new personnel. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No 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.