EIN: 416000464
UEI: KFQ8PQAHCN53
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 24, 2026. 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 September 24, 2026 (30 days from today).
What is a management decision? →The District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: One of the two covered transactions selected for testing lacked formal control documentation showing that the District completed the required suspension and debarment verification before entering into the contract. The verification was instead performed and documented at a later date. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2024-004 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2025 - 001: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 252MN061N1199, 2025 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal 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 District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: One of the two covered transactions selected for testing lacked formal control documentation showing that the District completed the required suspension and debarment verification before entering into the contract. The verification was instead performed and documented at a later date. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2024-004 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
Material Weakness in Internal Control Over Compliance Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procedures and policies over procurement and suspension and debarment to ensure that the District performs the proper suspension and debarment procedures prior to entering into a covered transaction, either through a sam.gov check or by including self-certification language in the contract and retain documentation of this process. Name(s) of the contact person(s) responsible for corrective action: David Brecht, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2026
2024-004
The District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: The one covered transaction selected for testing lacked formal control documentation showing that the District completed the required suspension and debarment verification before entering into the contract. The verification was instead performed and documented at a later date. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2024-005 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. Also, the District should ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2025 - 002: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Special Education Cluster ALN: 84.027 and 84.173 Federal Award Identification Numbers and Year: H027A240087 & H173A240086, 2025 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A230087 & H173A230086 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Special Education Cluster, per the requirements of 2 CFR §200.303. 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 District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: The one covered transaction selected for testing lacked formal control documentation showing that the District completed the required suspension and debarment verification before entering into the contract. The verification was instead performed and documented at a later date. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2024-005 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. Also, the District should ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
Material Weakness in Internal Control Over Compliance and Other Matters 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. Also, the District should ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procedures and policies over procurement and suspension and debarment to ensure that the District performs the proper suspension and debarment procedures prior to entering into a covered transaction, either through a sam.gov check or by including self-certification language in the contract and retain documentation of this process. Name(s) of the contact person(s) responsible for corrective action: David Brecht, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2026
2024-005
FAC accepted this audit on January 1, 2025 — management decision was due July 1, 2025.
The District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 - 004: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Child Nutrition Cluster, per the requirements of 2 CFR §200.303. The Uniform Guidance requires that when a nonfederal 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 District did not retain formal documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of three covered transactions tested, it was noted that the District did not retain formal documentation of a control over the required verifications on all three of the transactions. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
Material Weakness in Internal Control Over Compliance Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procedures and policies over procurement and suspension and debarment to ensure that the District performs the proper suspension and debarment procedures prior to entering into a covered transaction, either through a sam.gov check or by including self-certification language in the contract. Name(s) of the contact person(s) responsible for corrective action: David Brecht, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2025
2023-003
The District did not perform the required verification procedures before entering into over covered transactions in the special education program for fiscal year 2024, and the District therefore also did not retain documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of two covered transactions tested, it was noted that the District did not perform the required control over verifications on two of two. It was noted during testing and review of SAM.gov, however, that none of the vendors used were suspended or debarred. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 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. Also, the District should ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 - 005: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Special Education Cluster ALN: 84.027 and 84.173 Federal Award Identification Numbers and Year: H027A230087 & H173A230086, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A230087 & H173A230086 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Criteria or Specific Requirement: The District should have controls in place to ensure compliance with suspension and debarment requirements of the Special Education Cluster, per the requirements of 2 CFR §200.303. 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 District did not perform the required verification procedures before entering into over covered transactions in the special education program for fiscal year 2024, and the District therefore also did not retain documentation of a control to ensure timely completion of suspension and debarment requirements. Questioned Costs: None Context: Of two covered transactions tested, it was noted that the District did not perform the required control over verifications on two of two. It was noted during testing and review of SAM.gov, however, that none of the vendors used were suspended or debarred. Cause: The District’s policies and procedures did not include formal documentation of a control to ensure vendors are checked for suspension and debarment prior to entering covered transactions. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: Yes – 2023-003 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. Also, the District should ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. View of Responsible Official: There is no disagreement with the audit finding.
Material Weakness in Internal Control Over Compliance and Other Matters 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. Also, the District should ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will revise its procurement and suspension/debarment procedures to fully align with the Uniform Guidance requirements. The District will implement a process to verify vendors for suspension and debarment prior to entering into any covered transactions. Name(s) of the contact person(s) responsible for corrective action: David Brecht, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2025
2023-003
The District did not retain formal documentation of controls over procurement procedures over covered transactions in the child nutrition program in 2024. Questioned Costs: None Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 2 of 40 items tested for the child nutrition program. Cause: Although it was determined that compliance requirements were met through corroboration with multiple District staff and contractors as well as confirmation that one of the noted procurements in question was purchased through a group purchasing cooperation, the documentation of related controls was not formally documented or retained. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 - 006: Procurement Federal Agencies: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, and 10.559 Federal Award Identification Number and Year: 23MIN061N1199, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0112-000 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District did not retain formal documentation of controls over procurement procedures over covered transactions in the child nutrition program in 2024. Questioned Costs: None Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 2 of 40 items tested for the child nutrition program. Cause: Although it was determined that compliance requirements were met through corroboration with multiple District staff and contractors as well as confirmation that one of the noted procurements in question was purchased through a group purchasing cooperation, the documentation of related controls was not formally documented or retained. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
Material Weakness in Internal Control Over Compliance Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its policies and procedures to ensure that all required documentation, including quotes, bids, and the formal rationale for procurement decisions, is retained in compliance with best practices and applicable regulations. These updates will include clear guidelines for procurement methods, documentation requirements, and accountability measures to ensure compliance moving forward. Name(s) of the contact person(s) responsible for corrective action: David Brecht, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2025
The District did not perform the required control over procurement procedures over covered transactions in the special education program in 2024. Questioned Costs: $19,317 Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 3 of 3 items tested for the special education program. Cause: District did not retain the proper documentation for the procurement method utilized. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 - 007: Procurement Federal Agency: U.S. Department of Education Federal Program Title: Special Education Cluster ALN: 84.027 and 84.173 Federal Award Identification Numbers and Year: H027A230087 & H173A230086, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A230087 & H173A230086 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District did not perform the required control over procurement procedures over covered transactions in the special education program in 2024. Questioned Costs: $19,317 Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 3 of 3 items tested for the special education program. Cause: District did not retain the proper documentation for the procurement method utilized. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
Material Weakness in Internal Control Over Compliance and Other Matters Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procurement procedures and policies to ensure compliance with documentation requirements. Specifically, the District will implement a system to retain all quotes/bids received and formally document rationale for all procurement decisions. Name(s) of the contact person(s) responsible for corrective action: David Brecht, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2025
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
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.
Show full finding ▾Hide full finding ▴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.
Material Weakness in Internal Control Over Compliance and Compliance Finding 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. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procedures and policies over procurement to ensure that the District performs the proper suspension and debarment procedures prior to entering into a covered transaction, either through a sam.gov check or by including self-certification language in the contract. Name(s) of the contact person(s) responsible for corrective action: Molly Lopez, Finance Manager. Planned completion date for corrective action plan: June 30, 2024
2022-001
FAC accepted this audit on November 22, 2022 — management decision was due May 22, 2023.
The School District did not perform the required verification procedures over covered transactions in the child nutrition program in fiscal year 2022. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on any of the five. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Cause: The District has had turnover in some roles within the Child Nutrition program and not all of the program requirements were known to new personnel. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No 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.
Show full finding ▾Hide full finding ▴Federal Agencies: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster ALN: 10.553, 10.555, 10.556, 10.559 Pass-Through Agency: Minnesota Department of Education Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding Criteria: 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 in the child nutrition program in fiscal year 2022. Context: Of five covered transactions tested, it was noted that the District did not perform the required verifications on any of the five. Subsequently the District performed the required verifications and identified that none of the vendors used were suspended or debarred. Questioned Costs: None Cause: The District has had turnover in some roles within the Child Nutrition program and not all of the program requirements were known to new personnel. Effect: The District could have entered into a covered transaction with an entity which was suspended or debarred without realizing it. Repeat Finding: No 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.
2022-001 Material Weakness in Internal Control Over Compliance and Compliance Finding 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. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procedures and policies over procurement to ensure that the District performs the proper suspension and debarment procedures prior to entering into a covered transaction, either through a sam.gov check or by including self-certification language in the contract. Name(s) of the contact person(s) responsible for corrective action: Pam Jensen, Finance Manager. Planned completion date for corrective action plan: June 30, 2023
FAC accepted this audit on October 13, 2016 — management decision was due April 13, 2017.
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