Independent School District No. 621

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCES OF NONCOMPLIANCE ? U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER ? CFDA NOS. 10.553, 10.555, 10.556, AND 10.559 2020-001 Internal Control and Compliance With Federal Procurement Requirements Criteria ? 2 CFR ? 200.320(b) requires Independent School District No. 621, Mounds View Public Schools (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement requirements applicable to the child nutrition cluster program. Condition ? During our audit, we noted that the District did not have sufficient controls in place within its child nutrition cluster federal program to assure compliance with federal procurement requirements, which resulted in noncompliance. For 4 of 14 vendors tested, the District had not awarded a contract based on sealed bids or quotations as required by the Uniform Guidance. Questioned Costs ? None noted. Context ? Four of fourteen vendors tested were not in compliance. This was not a statistically valid sample. Repeat Finding ? This is a current year finding. Cause ? This was an oversight by district personnel. Effect ? Noncompliance with the procurement requirements could result in the District expending federal funds with vendors prior to obtaining bids or quotes if required, which could be viewed as a violation of the award agreement. Recommendation ? We recommend that the District review its internal control procedures relating to procurement for all federal programs. The District should verify compliance with federal procurement procedures, including awarding contracts based on sealed bids or quotations for the purchase of goods or services exceeding applicable federal dollar thresholds. View of Responsible Official and Planned Corrective Actions ? The District agrees with the finding. The District intends to review its procedures relating to procurement for its federal programs, and will ensure that bids and/or quotations are obtained when required. The District has separately issued a Corrective Action Plan related to this finding.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES ? CFDA NO. 84.010 2019-001 Internal Control Over Compliance With Federal Allowable Costs Requirements Criteria ? 2 CFR ? 200.302(b)(3) requires Independent School District No. 621, Mounds View Public Schools (the District) to maintain records that adequately identify the source and application of funds for federally-funded activities in accordance with 2 CFR 200 Subpart E ? Cost Principles. Condition ? During our audit, we noted that the District did not have sufficient controls to ensure adequate and timely documentation of time and effort was created and retained to support salary costs charged to federal programs and ensure compliance with the U.S. Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) allowable costs standards. Questioned Costs ? $11,675. Context ? The deficiency in internal controls over compliance pertains to major programs tested in the current year. This was not a statistically valid sample. Repeat Finding ? This is a current year finding only. Cause ? This was an oversight by district personnel. Effect ? This could be viewed as a violation of the award agreement. Recommendation ? We recommend that the District review its internal control procedures relating to time and effort documentation of allowable costs for Title I federal programs. View of Responsible Official and Planned Corrective Actions ? The District agrees with the finding. The District will review and update its policies and procedures relating to allowable costs for its federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.

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