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:
• Significant Deficiency 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. 2 CFR §200.318 - §200.321 requires that all procurement transactions be conducted in a manner providing full and open competition consistent with the standards of the section. Procurement by noncompetitive proposals may be utilized if the item is available only from a single source, however efforts must be made and the process fully documented in order to conclude that the use of a sole source procurement is appropriate.
Condition: It was noted during procurement testing that, for one contract, the District did not utilize quotes, sealed bids, or competitive proposals for the noted procurement, and any sole course conclusions were also not documented.
Questioned Costs: ALN 84.027 and 84.173, Federal Award Identification Number H027A220087 and H173A180086: $4,502
Context: Of the two procurements tested in the Special Education Cluster, one was missing documentation to support a proper procurement method.
Cause: The District procedures do not contain sufficient guidelines for ensuring all procurements utilize the proper method and are properly documented.
Effect: The lack of proper methods and documentation could lead to using vendors for small purchase acquisitions without ensuring comparable pricing from other vendors and justifying costs.
Repeat Finding: Yes – 2022-002.
Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used.
View of Responsible
Official: There is no disagreement with the audit finding.