Independent School District NO. 191

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER PROCUREMENT ? STATE AND LOCAL FISCAL RECOVERY FUNDS Condition: During our audit we noted no formal record was retained of a comparison of rates or prices to other emotional health services for a procurement purchase over the threshold of $250,000. Criteria or Specific requirement: The District should have controls in place to ensure compliance with procurement requirements of the State and Local Fiscal Recovery Fund program. This includes approving all purchases and performing a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Effect: Lack of proper procedures and controls related to the procurement could result in improper contracts being paid with federal funds. The District could also possibly award a contract to a vendor that would charge more than other responsible bidders due to not having performed cost analysis. Cause: The vendor has been utilized by the District for over ten years as a professional service. The District recently charged it to federal funds to supplant some of their other costs. The District was unable to locate the original documents for the contract to determine if they were still under a professional services contract or not, and was not able to come up with any other type of documentation showing the required cost analysis. Questioned Costs: $50,000 Context: One of the five contracts tested did not have supporting documentation following procurement guidelines. Recommendation: We recommend that the District ensures it retains documentation of its controls over all procurements going forward. We also recommend that the district keep documentation of price analysis for procurement items over the micro purchase threshold of $10,000. Prior Year Finding? No Views of responsible officials: There is no disagreement with the audit finding.

FINDING: 2020-001 MATERIAL WEAKNESS IN INTERNAL CONTROL OVER SUSPENSION AND DEBARMENT Federal Agency: U.S. Department of Education Federal Program Title: Special Education Cluster CFDA Number: 84.027 and 84.173 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087 and H173A180086 Award Period: Year ended June 30, 2020 Condition: The District did not retain formal documentation of its testing and controls to ensure that all vendors over the $25,000 contract threshold on a District-wide basis were not suspended or debarred prior to awarding the related contracts. Criteria: 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: 1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA); 2) collecting a certification from the entity; or 3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Effect: Lack of proper procedures and controls related to the suspension and debarment could result in improper contracts with suspended or debarred vendors being paid with federal funds. Cause: District has been unaware of formal documentation suspension and debarment requirements on a District-wide basis for any contract or procurement with all or part of the contract coded to the Special Education Cluster. Questioned Costs: None Context: None of the 5 contracts tested included formal documentation of the District?s testing and controls to ensure that all vendors over the $25,000 contract threshold on a District-wide basis were not suspended or debarred prior to awarding the related contracts. Recommendation: We recommend that the District create and review its related policies and procedures to ensure it is retaining documentation showing that the District crosschecked the vendors with procurements over the threshold of $25,000 at the time of procurement. Prior Year Finding? No Views of responsible officials: There is no disagreement with the audit finding.

Finding 2019-002 SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER SPECIAL TESTS AND PROVISION Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.553, 10.555, 10.556, and 10.559 Pass-Through Agency: Minnesota Department of Agriculture Pass-Through Number: 01-492-000 Award Period: Year ended June 30, 2019 Condition: During our verification special provision testing, we noted that there were no formal documentation indicating who completed the testing or who reviewed the verification testing that was completed by other District staff. Criteria: By November 15th of each year, the District must verify the current free and reduced price eligibility of households selected from a sample of applications that it has approved for free and reduced price meals. The District should also have controls over this compliance requirement to ensure this procedure is being completed properly and in a timely manner. Effect: Lack of proper procedures and controls related to the verification special provision, could result in errors going undetected and ineligible meals being charged to the program. Cause: Due to turnover and the District had implemented new procedures related to this process in fiscal year 2018, and District staff had forgot to formally document who completed the testing and who reviewed the testing and changes in eligibility that came about from the verification procedures. Questioned Costs: None Context: 3 of the 5 files reviewed did not include formal documentation indicating who completed the testing and no formal documentation of review of the verification testing that was completed by District staff. Recommendations: We recommend that the District start formally documenting who is completing the verification testing and have someone documenting their review of the work, including that any changes that come about from the tests are properly reflected in the District?s student software. Prior Year Finding: Yes Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. The Executive Director of Business Services and Director of Accounting will continue training staff on financial procedures and responsibilities.

FINDINGL 2019-003: SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER SUSPENSION AND DEBARMENT Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.553, 10.555, 10.556, and 10.559 Pass-Through Agency: Minnesota Department of Agriculture Pass-Through Number: 01-492-000 Award Period: Year ended June 30, 2019 Condition: The District did not retain formal documentation of its testing and controls to ensure that all vendors over the $25,000 contract threshold on a District-wide basis were not suspended or debarred prior to awarding the related contracts. Criteria: 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: 1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA); 2) collecting a certification from the entity; or 3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Effect: Lack of proper procedures and controls related to the suspension and debarment could result in improper contracts with suspended or debarred vendors being paid with federal funds. Cause: District has been unaware of formal documentation suspension and debarment requirements on a District-wide basis for any contract or procurement with all or part of the contract coded to the Food Service Fund. Questioned Costs: None Contect: None of the 5 contracts tested included formal documentation of the District?s testing and controls to ensure that all vendors over the $25,000 contract threshold on a District-wide basis were not suspended or debarred prior to awarding the related contracts. Recommendation: We recommend that the District creates reviews its related policies and procedures to ensure it is retaining documentation showing that the District crosschecked the vendors with procurements over the threshold of $25k at the time of procurement.

GSA_MIGRATION

GSA_MIGRATION