Lake Region Special Education

Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension and debarment it was identified that the District’s policy and procedures did not include periodic checks over vendors for suspension or debarment. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs – None reported Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No Recommendation – We recommend that management establish a written policy and procedures that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.

Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs – None reported Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – Yes, prior year finding 2022-004 Recommendation – We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.

Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria ? Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition ? In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause ? Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect ? A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs ? None reported Context/Sampling ? Overall procurement policy. Repeat Finding from Prior Years ? No Recommendation ? We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials ? There is no disagreement with the audit finding.

Department of Education, Passed Through the North Dakota Department of Public Instruction CFDA No. 84.027/84.173 Special Education Period of Performance Significant Deficiency in Internal Control over Compliance Criteria ? A good system of internal accounting control includes an adequate system for ensuring that all period of performance requirement are met, documented and approved. Condition ?During the course of our engagement we noted that the District included a 2019 and a 2021 expense in their 2020 reimbursement. Cause ? Control procedures in place did not detect the expenditures coded to the correct period. Effect ? These expenditures are included in the wrong period. Questioned Costs ? None reported. The total of known and projected questioned costs were less than the threshold that would require reporting. Context/Sampling ? A nonstatistical sample of 60 transactions were selected for testing which accounted for $384,889 of $1,197,312 of federal program expenditures. Repeat Finding from Prior Years ? No Recommendation ? Management should take steps to ensure that all federal expenditures should be in the correct period under Uniform Guidance. Views of Responsible Officials ? There is no disagreement with the audit finding.