ROWVA Community Unit School District No. 208Local Government

Criteria or specific requirement: Internal controls should be designed to allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements and safeguard assets. A concept in a good system of internal control is adequate segregation of duties. Condition: A limited number of employees have the primary responsibility for performing most of the accounting and financial duties including key functions of recording, reconciling, and reporting cash transactions. This structure reduces certain aspects of the internal control system which rely on adequate segregation of duties. Context: All District accounting and financial records are maintained by a limited number of employees. Effect: Limited segregation of duties increases the risk that employees, in the normal course of performing their assigned functions will not prevent or detect misstatements and safeguard assets. Cause: A limited number of employees have the ability to complete and record accounting functions which ideally would be segregated. Recommendation: Segregation of duties is normally difficult to accomplish with a small governmental entity. Management should be mindful of areas that could be improved including, but not limited to, hiring additional personnel. Management's response: Currently, the District relies on management oversight and budgetary controls to help mitigate the effects of a limited number of accounting personnel. The District will review the internal control system annually and when the benefits of hiring additional personnel can be realized on a cost effective basis, the District will pursue this option.

Criteria or specific requrement: The District did not obtain debarment certification or document their vendor search in the System for Award Management website for vendors contracted in excess of $25,000 related to the grant program. Upon further review, it was determined that the vendors were not suspended or debarred. Questioned costs: None. Context: The District did not document their verification that selected vendors were not suspended or debarred. Effect: Noncompliance with the federal program's suspension and debarment compliance requirement could occur and not be detected and corrected in a timely manner. Cause: Written procedures are not in place to verify if vendors contracted in excess of $25,000 related to the Child Nutrition Cluster program are not suspended, debarred, or otherwise excluded from doing business. Recommendation: Procedures need to be implemented to ensure all vendors contracted with have not been suspended, debarred, or otherwise excluded from doing business, prior to procuring their services. Management's response: Management does not disagree with this finding. In future years, the District will document their verification that vendors are not suspended, debarred, or otherwise excluded from doing business.

Criteria or specific requirement (including statutory, regulatory, or other citation) - The Code of Federal Regulations (CFR) Title 2, Part 180.220 states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. Condition - The District did not obtain debarment certification or document their vendor search in the System for Award Management website for vendors contracted in excess of $25,000 related to the grant program. Upon further review, it was determined that the vendors were not suspended or debarred. Questioned Costs - None. Context - The District did not document their verification that selected vendors were not suspended or debarred. Effect - Noncompliance with the federal award program's suspension and debarment compliance requirement could occur and not be detected and corrected in a timely manner. Cause - Written procedures are not in place to verify if vendors contracted in excess of $25,000 related to the Child Nutrition Cluster program are not suspended, debarred, or otherwise excluded from doing business. Recommendation - Procedures need to be implemented to ensure all vendors contracted with have not been suspended, debarred, or otherwise excluded from doing business, prior to procuring their services. Management's response - Management does not disagree with this finding. In future years, the District will document their verification that vendors are not suspended, debarred, or otherwise excluded from doing business.