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: H027A220087, 2023
Pass-Through Agency: Minnesota Department of Education
Pass-Through Number: H027A190087
Award Period: Fiscal year 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement:2 CFR § 180.300 requires that before the District enters into a covered transaction with an entity at a lower tier, the District 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. 2 CFR 200.303 requires that the entity have sufficient controls over compliance related to federal awards.
Condition: In our testing for the Special Education Cluster, we noted instances where there was no documentation of this verification being performed.
Questioned Costs: None
Context: During testing of the program, it was noted that four of five contracts that were tested were entered into without the District verifying and retaining documentation of said verification that the vendors were not suspended or debarred by the federal government.
Cause: The District’s practice of ensuring sam.gov was checked for all contracts entered into and documentation retained was not performed as expected during the pandemic, and thereafter during fiscal year 2023 within the special education program.
Effect: The District was not in compliance with federal suspension and debarment requirements.
Repeat Finding: Yes, 2022-003.
Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained.
Views of responsible officials: There is no disagreement with the audit finding.