Finding 963521 (2023-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-03-28

AI Summary

  • Core Issue: The School District failed to verify suspension and debarment status for vendors in federal programs, risking compliance violations.
  • Impacted Requirements: Compliance with Uniform Guidance and internal controls for the Child Nutrition Cluster and Special Education programs.
  • Recommended Follow-Up: Ensure adherence to procurement policies and perform required verifications for all federal transactions to prevent future issues.

Finding Text

2023 - 003: Suspension and Debarment Federal Agencies: U.S. Department of Agriculture & U.S. Department of Education Federal Program Title: Child Nutrition Cluster & Special Education ALN: 10.553, 10.555, 10.556, 10.559 & 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria or Specific Requirement: 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 for four of the five items tested in the child nutrition program in fiscal year 2023. The School district also did not perform the required verification procedures over two of the three tested items in the special education program for fiscal year 2023. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on four of the transactions for the child nutrition program and two of the three transactions tested for the special education program. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes 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.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 387075 2023-003
    Material Weakness Repeat
  • 387076 2023-003
    Material Weakness Repeat
  • 387077 2023-003
    Material Weakness Repeat
  • 387078 2023-003
    Material Weakness Repeat
  • 387079 2023-003
    Material Weakness Repeat
  • 387080 2023-003
    Material Weakness Repeat
  • 387081 2023-003
    Material Weakness Repeat
  • 387082 2023-003
    Material Weakness Repeat
  • 963517 2023-003
    Material Weakness Repeat
  • 963518 2023-003
    Material Weakness Repeat
  • 963519 2023-003
    Material Weakness Repeat
  • 963520 2023-003
    Material Weakness Repeat
  • 963522 2023-003
    Material Weakness Repeat
  • 963523 2023-003
    Material Weakness Repeat
  • 963524 2023-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States $464,234
10.553 School Breakfast Program $312,527
84.010 Title I Grants to Local Educational Agencies $304,304
10.555 National School Lunch Program $170,749
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $153,323
84.367 Supporting Effective Instruction $101,161
84.365 English Language Acquisition State Grants $66,213
84.181 Special Education-Grants for Infants and Families $46,420
84.173 Special Education_preschool Grants $40,221
84.048 Career and Technical Education -- Basic Grants to States $14,487
21.027 Coronavirus State and Local Fiscal Recovery Funds $6,375
10.558 Child and Adult Care Food Program $5,483
84.060 Indian Education_grants to Local Educational Agencies $4,322
10.649 Pandemic Ebt Administrative Costs $3,256
84.425 Education Stabilization Fund $206
10.556 Special Milk Program for Children $25