Finding 621657 (2022-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-30

AI Summary

  • Core Issue: The District lacks effective controls to ensure compliance with federal suspension and debarment requirements for vendors in the COVID-19 funding program.
  • Impacted Requirements: 2 CFR 180 mandates that the District verify vendors are not suspended or debarred before contracting for federal program expenditures.
  • Recommended Follow-Up: The District should enhance its internal controls by verifying vendor eligibility against the federal Excluded Parties List for contracts exceeding $25,000.

Finding Text

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION AND INDEPENDENT SCHOOL DISTRICT NO. 270, HOPKINS, COVID-19 ? CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS ? FEDERAL ALN 21.027 2022-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Criteria ? 2 CFR ? 180 requires Independent School District No. 283 (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 COVID-19 ? 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 COVID-19 ? 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 one vendor tested to ensure the vendor was not suspended or debarred from participation in federal program contracts. This was not a statistically valid sample. 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 COVID-19 ? 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.

Categories

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

Other Findings in this Audit

  • 45214 2022-003
    Significant Deficiency
  • 45215 2022-003
    Significant Deficiency
  • 621656 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $4.46M
84.010 Title I Grants to Local Educational Agencies $598,282
10.553 School Breakfast Program $456,492
10.555 National School Lunch Program $252,594
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $248,942
84.367 Supporting Effective Instruction State Grants $127,545
32.009 Emergency Connectivity Fund Program $84,396
84.027 Special Education_grants to States $75,734
10.559 Summer Food Service Program for Children $72,280
84.365 English Language Acquisition State Grants $72,274
84.173 Special Education_preschool Grants $41,068
84.424 Student Support and Academic Enrichment Program $39,074
84.048 Career and Technical Education -- Basic Grants to States $35,239
84.181 Special Education-Grants for Infants and Families $33,281
21.027 Coronavirus State and Local Fiscal Recovery Funds $17,400