Special School District of St. Louis County

2022-002 Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.173 and 84.027 Federal Award Identification Number and Year: H027A210040, 2023; H027A220040, 2023; H027X210040, 2023; H173A210103, 2023; H173A220103, 2023 Award Period: 2023 Pass-through Entity: 096-119 Questioned Costs: None Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement Some federal programs are subject to suspension and debarment requirements, which are designed to ensure that federal funds are not awarded to individuals or entities that have a history of noncompliance with federal regulations or that pose a risk to the integrity of federal programs. The suspension and debarment regulations require recipients of federal funding to ensure contractors and subrecipients are not suspended or debarred by the federal government prior to executing a contract. Condition: The District’s internal controls over compliance are not designed to ensure compliance with the suspension and debarment requirements. Context: Procurement was direct and material to the Special Education Cluster. For five of the seven contracts selected for testing, the District did not have evidence to support that the suspension and debarment process was performed. Cause: The District has not designed and implemented internal controls to ensure compliance with suspension and debarment requirements outlined in 2 CFR sections 416.1(a), 416.1(b) and 417.215(a)(1) and in 7 CFR section 210.21(g), 215.14a(e), 220.16(f), and 225.17(e). Effect: Federal funding could be spent on organizations that are suspended or disbarred Recommendation: We recommend the District implement internal control to ensure that suspension and debarment assessment are performed during the procurement and contracting phase. In addition, sufficient documentation should be retained to evidence suspension and debarment is performed. Repeat Finding: No Views of Responsible Officials: There is no disagreement with the audit finding.

Type: Significant Deficiency in Internal Control over Financial Reporting Recommendation: The District should implement processes to ensure revenue is recognition and reporting in the correct reporting period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District has identified new processes to ensure all revenue is recognized in the correct reporting period. Name(s) of the contact person(s) responsible for corrective action: Deedra Sagerty Planned completion date for corrective action plan: December 31, 2023