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BEMIDJI REGIONAL INTERDISTRICT COUNCIL NO. 998Local Government

EIN: 410987652

UEI: XCC3G1AKNGS5

Audited by: BRADY MARTZ, LLC

Oversight agency: 84 [Department of Education]

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Data as of September 2, 2026

BEMIDJI REGIONAL INTERDISTRICT COUNCIL NO. 99810 audit years9 findings6 repeat
10
Audit Years
9
Total Findings
6
Repeat Findings
$2.4M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$2,418,006 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on December 16, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 16, 2026 (79 days ago).

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2025-003
Activities Allowed or Unallowed / Cost Allowability / Period of Performance
SIGNIFICANT DEFICIENCY

AL#84.027 and #84.173 Special Education – Grants to States (IDEAS, Part B) Special Education Cluster award year 2025. Activities Allowed or Unallowed and Allowable Costs/Cost Principles (AB) Period of Performance (H) Criteria The Council’s policy is to ensure either the direct supervisor or executive director approves all non-payroll transactions. Furthermore, the Council has a policy that all wages are approved and signed off by the Business Manager. Condition During testing, we haphazardly selected 40 transactions and we noted 2 payroll transactions and one non-payroll transaction that did not have proper approval. Cause Management oversight. Effect There is an increased risk of charging an unallowable expense to the program. Questioned Costs Not applicable. Repeat Finding No. Recommendation We recommend the Council follow their internal control policy over disbursements. Management’s Response The Council is in agreement with the recommendation.

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AL#84.027 and #84.173 Special Education – Grants to States (IDEAS, Part B) Special Education Cluster award year 2025. Activities Allowed or Unallowed and Allowable Costs/Cost Principles (AB) Period of Performance (H) Criteria The Council’s policy is to ensure either the direct supervisor or executive director approves all non-payroll transactions. Furthermore, the Council has a policy that all wages are approved and signed off by the Business Manager. Condition During testing, we haphazardly selected 40 transactions and we noted 2 payroll transactions and one non-payroll transaction that did not have proper approval. Cause Management oversight. Effect There is an increased risk of charging an unallowable expense to the program. Questioned Costs Not applicable. Repeat Finding No. Recommendation We recommend the Council follow their internal control policy over disbursements. Management’s Response The Council is in agreement with the recommendation.

Corrective Action Plan

1. Correcting Plan Council will review and update internal control policies and procedures over cash disbursements. 2. Explanation of Disagreement with the Audit Findings There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Executive Director, Renae Donaghue, is responsible for carrying out the corrective action plan. 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Director will monitor completion of the CAP.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Period of Performance →
2025-004
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

AL#84.027 and #84.173 Special Education – Grants to States (IDEAS, Part B) Special Education Cluster award year 2025. Reporting (L) Criteria The Uniform Guidance states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition During review on the Federal Audit Clearinghouse website, we noted that the last submission of the Council’s audited financial statements was fiscal year ended June 30, 2020. Context. We reviewed the one required report. Cause Management oversight. Effect The Council is not in compliance with Uniform Guidance’s reporting requirements. Questioned Costs Not applicable. Repeat Finding No. Recommendation We recommend the Council implement controls to ensure all required reports are filed timely. Management’s Response The Council is in agreement with the recommendation.

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AL#84.027 and #84.173 Special Education – Grants to States (IDEAS, Part B) Special Education Cluster award year 2025. Reporting (L) Criteria The Uniform Guidance states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition During review on the Federal Audit Clearinghouse website, we noted that the last submission of the Council’s audited financial statements was fiscal year ended June 30, 2020. Context. We reviewed the one required report. Cause Management oversight. Effect The Council is not in compliance with Uniform Guidance’s reporting requirements. Questioned Costs Not applicable. Repeat Finding No. Recommendation We recommend the Council implement controls to ensure all required reports are filed timely. Management’s Response The Council is in agreement with the recommendation.

Corrective Action Plan

1. Correcting Plan The Council will implement an internal control policy to ensure that all reporting is filed timely. 2. Explanation of Disagreement with the Audit Findings There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Executive Director, Renae Donaghue, is responsible for carrying out the corrective action plan. 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP updates to the Board of Education, on an annual basis.

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FY 2024-06-30

$2,393,417 federal awards expendedNo findings recorded this year

FAC accepted this audit on September 10, 2025 — management decision was due March 10, 2026.

FY 2023-06-30

$2,361,247 federal awards expendedNo findings recorded this year

FAC accepted this audit on September 10, 2025 — management decision was due March 10, 2026.

FY 2022-06-30

$2,175,472 federal awards expendedNo findings recorded this year

FAC accepted this audit on December 22, 2025 — management decision was due June 22, 2026.

FY 2021-06-30

$2,075,815 federal awards expended

FAC accepted this audit on December 22, 2025 — management decision was due June 22, 2026.

2021-001
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2020-001

Condition One basic objective of internal control is to provide for segregation of incompatible duties. In other words, responsibilities should be separated among employees so that a single employee is not able to authorize a transaction, record the transaction in accounts, and be responsible for custody of the asset resulting from the transaction. The following duties are not sufficiently segregated: 1. Accounts payable processing, check writing, payment and recording. 2. Payroll processing, check writing, check distribution and recording. 3. Cash receipting, depositing and recording. Together these functions create an opportunity for misappropriation of the Council’s assets and more than a remote likelihood of a material misstatement. The Council does mitigate control in accounts payable and payroll functions in that the Board, on a monthly basis, reviews the invoices and checks that are written. Criteria Proper segregation of duties mitigates the risk of misappropriation of assets. Effect The impact to the financial statements has not been determined. Cause The Council operates in an environment that is highly regulated and funded by the State of Minnesota through the Department of Education. As a result of this regulatory oversight and the level of funding, the Council did not feel it was at liberty to fund the additional positions necessary to achieve adequate accounting control. Repeat Finding Yes, 2020-001 Recommendation We recommend that Council management develop an accounting and internal control manual that would identify the specific duties of the accounting employees with internal controls and segregation of accounting duties in mind.

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Condition One basic objective of internal control is to provide for segregation of incompatible duties. In other words, responsibilities should be separated among employees so that a single employee is not able to authorize a transaction, record the transaction in accounts, and be responsible for custody of the asset resulting from the transaction. The following duties are not sufficiently segregated: 1. Accounts payable processing, check writing, payment and recording. 2. Payroll processing, check writing, check distribution and recording. 3. Cash receipting, depositing and recording. Together these functions create an opportunity for misappropriation of the Council’s assets and more than a remote likelihood of a material misstatement. The Council does mitigate control in accounts payable and payroll functions in that the Board, on a monthly basis, reviews the invoices and checks that are written. Criteria Proper segregation of duties mitigates the risk of misappropriation of assets. Effect The impact to the financial statements has not been determined. Cause The Council operates in an environment that is highly regulated and funded by the State of Minnesota through the Department of Education. As a result of this regulatory oversight and the level of funding, the Council did not feel it was at liberty to fund the additional positions necessary to achieve adequate accounting control. Repeat Finding Yes, 2020-001 Recommendation We recommend that Council management develop an accounting and internal control manual that would identify the specific duties of the accounting employees with internal controls and segregation of accounting duties in mind.

Corrective Action Plan

Management’s Response – Corrective Action Plan 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding A. Review current segregation of duties among existing staff within administrative office that have any assigned duties relative to the financial operations of the Council. B. Determine appropriate approval and oversight of all journal entries. Continue to require dual signatures on all checks and approval of all expenditures monthly by the Board. Consider all correspondence received relative to finance (bank statements, financial statements, other) be received by the Executive Director’s office unopened upon receipt. Executive Director will review journal entries and bank (financial) reconciliations and sign off monthly. 3. Official Responsible for Ensuring CAP Implementation Brenda Story, Executive Director 4. Planned Completion of CAP Reviewed annually. 5. Plan to Monitor Completion of CAP Executive Director will review any changes in duties on an annual basis.

Prior Finding References

2020-001

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FY 2020-06-30

LOW-RISK AUDITEE$2,082,222 federal awards expended

FAC accepted this audit on March 23, 2021 — management decision was due September 23, 2021.

2020-001
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2019-001

One basic objective of internal control is to provide for segregation of incompatible duties. In other words, responsibilities should be separated among employees so that a single employee is not able to authorize a transaction, record the transaction in accounts, and be responsible for custody of the asset resulting from the transaction. The following duties are not sufficiently segregated: 1. Accounts payable processing, check writing, payment and recording. 2. Payroll processing, check writing, check distribution and recording. 3. Cash receipting, depositing and recording. Together these functions create an opportunity for misappropriation of the Council?s assets and more than a remote likelihood of a material misstatement. The Council does mitigate control in accounts payable and payroll functions in that the Board, on a monthly basis, reviews the invoices and checks that are written. Criteria: Proper segregation of duties mitigates the risk of misappropriation of assets. Effect: The impact to the financial statements has not been determined. Cause: The Council operates in an environment that is highly regulated and funded by the State of Minnesota through the Department of Education. As a result of this regulatory oversight and the level of funding, the Council did not feel it was at liberty to fund the additional positions necessary to achieve adequate accounting control. Repeat Finding: Yes, 2019-001 Recommendation: We recommend that Council management develop an accounting and internal control manual that would identify the specific duties of the accounting employees with internal controls and segregation of accounting duties in mind.1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding Council will continue to have the contracted Auditor for the year prepare the financial statements. Council will consider internal control procedures consistent with those outlined above within the segregation of duties and with Board guidance (approval of policies and/or procedures). In addition, all financial statement review will be documented. 3. Official Responsible for Ensuring CAP Implementation Brenda Story, Executive Director 4. Planned Completion of CAP Annually, in October 5. Plan to Monitor Completion of CAP Documentation of the annual review of financial statements will be filed with the Council?s annual audit file.

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U.S. Department of Education. Pass-through Minnesota Department of Education. Special Education Cluster - CFDA No. 84.027 and 84.173. Segregation of Accounting Duties. Condition: One basic objective of internal control is to provide for segregation of incompatible duties. In other words, responsibilities should be separated among employees so that a single employee is not able to authorize a transaction, record the transaction in accounts, and be responsible for custody of the asset resulting from the transaction. The following duties are not sufficiently segregated: 1. Accounts payable processing, check writing, payment and recording. 2. Payroll processing, check writing, check distribution and recording. 3. Cash receipting, depositing and recording. Together these functions create an opportunity for misappropriation of the Council?s assets and more than a remote likelihood of a material misstatement. The Council does mitigate control in accounts payable and payroll functions in that the Board, on a monthly basis, reviews the invoices and checks that are written. Criteria: Proper segregation of duties mitigates the risk of misappropriation of assets. Effect: The impact to the financial statements has not been determined. Cause: The Council operates in an environment that is highly regulated and funded by the State of Minnesota through the Department of Education. As a result of this regulatory oversight and the level of funding, the Council did not feel it was at liberty to fund the additional positions necessary to achieve adequate accounting control. Repeat Finding: Yes, 2019-001 Recommendation: We recommend that Council management develop an accounting and internal control manual that would identify the specific duties of the accounting employees with internal controls and segregation of accounting duties in mind.1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding Council will continue to have the contracted Auditor for the year prepare the financial statements. Council will consider internal control procedures consistent with those outlined above within the segregation of duties and with Board guidance (approval of policies and/or procedures). In addition, all financial statement review will be documented. 3. Official Responsible for Ensuring CAP Implementation Brenda Story, Executive Director 4. Planned Completion of CAP Annually, in October 5. Plan to Monitor Completion of CAP Documentation of the annual review of financial statements will be filed with the Council?s annual audit file.

Corrective Action Plan

Department of Education Bemidji Regional Interdistrict Council respectively submits the following corrective action plans for the year ended June 30, 2020. Name and address of public accounting firm: Miller McDonald, Inc. 513 Beltrami Avenue Bemidji, MN 56601 Audit Period: June 30, 2020 The finding from the June 30, 2020, schedule of findings and questioned costs are discussed below. Finding: 2020-001 ? Segregation of Accounting Duties Corrective Action Plan Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Actions Planned in Response to Finding A. Review current segregation of duties among existing staff within administrative office that have any assigned duties relative to the financial operations of the Council. B. Determine appropriate approval and oversight of all journal entries. Continue to require dual signatures on all checks and approval of all expenditures monthly by the Board. Consider all correspondence received relative to finance (bank statements, financial statements, other) be received by the Executive Director?s office unopened upon receipt. Executive Director will review journal entries and bank (financial) reconciliations and sign off monthly. Official Responsible for Ensuring CAP Implementation Brenda Story, Executive Director Planned Completion of CAP Reviewed annually. Plan to Monitor Completion of CAP Executive Director will review any changes in duties on an annual basis.

Prior Finding References

2019-001

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FY 2019-06-30

$2,035,727 federal awards expended

FAC accepted this audit on September 30, 2019 — management decision was due March 30, 2020.

2019-001
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2018-001

One basic objective of internal control is to provide for segregation of incompatible duties. In other words, responsibilities should be separated among employees so that a single employee is not able to authorize a transaction, record the transaction in accounts, and be responsible for custody of the asset resulting from the transaction. The following duties are not sufficiently segregated: 1. Accounts payable processing, check writing, payment and recording. 2. Payroll processing, check writing, check distribution and recording. 3. Cash receipting, depositing and recording. Together these functions create an opportunity for misappropriation of the Council?s assets and more than a remote likelihood of a material misstatement. The Council does mitigate control in accounts payable and payroll functions in that the Board, on a monthly basis, reviews the invoices and checks that are written. Criteria: Proper segregation of duties mitigates the risk of misappropriation of assets. Effect: The impact to the financial statements has not been determined. Cause: The Council operates in an environment that is highly regulated and funded by the State of Minnesota through the Department of Education. As a result of this regulatory oversight and the level of funding, the Council did not feel it was at liberty to fund the additional positions necessary to achieve adequate accounting control. Repeat Finding: Yes, 2018-001 Recommendation: We recommend that Council management develop an accounting and internal control manual that would identify the specific duties of the accounting employees with internal controls and segregation of accounting duties in mind.

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Condition:One basic objective of internal control is to provide for segregation of incompatible duties. In other words, responsibilities should be separated among employees so that a single employee is not able to authorize a transaction, record the transaction in accounts, and be responsible for custody of the asset resulting from the transaction. The following duties are not sufficiently segregated: 1. Accounts payable processing, check writing, payment and recording. 2. Payroll processing, check writing, check distribution and recording. 3. Cash receipting, depositing and recording. Together these functions create an opportunity for misappropriation of the Council?s assets and more than a remote likelihood of a material misstatement. The Council does mitigate control in accounts payable and payroll functions in that the Board, on a monthly basis, reviews the invoices and checks that are written. Criteria: Proper segregation of duties mitigates the risk of misappropriation of assets. Effect: The impact to the financial statements has not been determined. Cause: The Council operates in an environment that is highly regulated and funded by the State of Minnesota through the Department of Education. As a result of this regulatory oversight and the level of funding, the Council did not feel it was at liberty to fund the additional positions necessary to achieve adequate accounting control. Repeat Finding: Yes, 2018-001 Recommendation: We recommend that Council management develop an accounting and internal control manual that would identify the specific duties of the accounting employees with internal controls and segregation of accounting duties in mind.

Corrective Action Plan

Department of Education Bemidji Regional Interdistrict Council respectively submits the following corrective action plans for the year ended June 30, 2019. Name and address of public accounting firm: Miller McDonald, Inc. 513 Beltrami Avenue Bemidji, MN 56601 Audit Period: June 30, 2019 The finding from the June 30, 2019, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2019-001 ? Segregation of Accounting Duties Corrective Action Plan Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Actions Planned in Response to Finding A. Review current segregation of duties among existing staff within administrative office that have any assigned duties relative to the financial operations of the Council. B. Determine appropriate approval and oversight of all journal entries. Continue to require dual signatures on all checks and approval of all expenditures monthly by the Board. Consider all correspondence received relative to finance (bank statements, financial statements, other) be received by the Executive Director?s office unopened upon receipt. Executive Director will review journal entries and bank (financial) reconciliations and sign off monthly. Official Responsible for Ensuring CAP Implementation Brenda Story, Executive Director Planned Completion of CAP Reviewed annually. Plan to Monitor Completion of CAP Executive Director will review any changes in duties on an annual basis. Finding 2019-002 ? Preparation of Financial Statements Corrective Action Plan Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Actions Planned in Response to Finding Council will continue to have the contracted Auditor for the year prepare the financial statements. Council will consider internal control procedures consistent with those outlined above within the segregation of duties and with Board guidance (approval of policies and/or procedures). In addition, all financial statement review will be documented. Official Responsible for Ensuring CAP Implementation Brenda Story, Executive Director Planned Completion of CAP Annually, in October Plan to Monitor Completion of CAP Documentation of the annual review of financial statements will be filed with the Council?s annual audit file. Finding 2019-003 ? Interest Not Paid on Late Bills Corrective Action Plan Explanation of Disagreement with Audit Findings No Disagreement Actions Planned in Response to Finding Secretary will make sure all invoices are stamped ?received? with a date when they come in, whether by mail, e-mail or fax. Official Responsible for Ensuring CAP Implementation Lisa Carlson, Business Manager Planned Completion of CAP Immediately Plan to Monitor Completion of CAP Business Office Assistant will review each invoice when preparing payments. When the 35 day deadline is not going to be met, she will notify the Business Manager why this has happened and will also make note of the reason on BRIC?s copy of the payment.

Prior Finding References

2018-001

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FY 2018-06-30

$1,940,027 federal awards expended

FAC accepted this audit on October 15, 2018 — management decision was due April 15, 2019.

2018-001
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2008-001

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2008-001

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FY 2017-06-30

LOW-RISK AUDITEE$1,802,841 federal awards expended

FAC accepted this audit on April 9, 2018 — management decision was due October 9, 2018.

2008-001
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2008-001

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2008-001

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FY 2016-06-30

LOW-RISK AUDITEE$1,903,701 federal awards expended

FAC accepted this audit on November 6, 2016 — management decision was due May 6, 2017.

2008-001
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2008-001

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2008-001

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2016-001
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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