Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Special Tests and Provisions – Verification of Applications
Type of Finding
Material weakness in internal control over compliance, Qualification
Criteria
The District is required to verify and support with documentation 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 as of October 1 and completed by November 15.
Condition
The District did not retain workpapers to support that the special tests and provision requirement to perform verification of free and reduced price applications was completed.
Context
The District has limited employees and does not have adequate segregation of duties over the grant management process to ensure that the documentation to support the verification process was retained.
Cause
The District did not retain documentation and other information to support their procedures over the compliance requirements of the program.
Effect
The District may have households that were not eligible for the status based on the documentation and other information obtained through the verification process.
Repeat Finding
Yes - 2022-004
Recommendation
We recommend the District establish procedures and controls over the retention of verification documentation and other information obtained through the verification process.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Special Tests and Provisions – Verification of Applications
Type of Finding
Material weakness in internal control over compliance, Qualification
Criteria
The District is required to verify and support with documentation 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 as of October 1 and completed by November 15.
Condition
The District did not retain workpapers to support that the special tests and provision requirement to perform verification of free and reduced price applications was completed.
Context
The District has limited employees and does not have adequate segregation of duties over the grant management process to ensure that the documentation to support the verification process was retained.
Cause
The District did not retain documentation and other information to support their procedures over the compliance requirements of the program.
Effect
The District may have households that were not eligible for the status based on the documentation and other information obtained through the verification process.
Repeat Finding
Yes - 2022-004
Recommendation
We recommend the District establish procedures and controls over the retention of verification documentation and other information obtained through the verification process.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Procurement
Type of Finding
Significant deficiency in internal control over compliance
Criteria
2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors.
Condition
During our testing of procurement transactions of the program we noted that 2 of 3 vendors selected were not supported by any price or rate quotations to ensure the District is prudent with the monies used towards the program.
Questioned Costs
None.
Context
The District's procurement did not conform to Uniform Guidance for 2 of 3 vendors tested in our sample.
Cause
The District did not follow Federal Funds Procurement policy.
Effect
Obtaining price or rate quotations from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services.
Repeat Finding
Yes – 2022-005Recommendation
We recommend the District review procurement policies and establish a procurement process in order to ensure this policy is being followed.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Procurement
Type of Finding
Significant deficiency in internal control over compliance
Criteria
2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors.
Condition
During our testing of procurement transactions of the program we noted that 2 of 3 vendors selected were not supported by any price or rate quotations to ensure the District is prudent with the monies used towards the program.
Questioned Costs
None.
Context
The District's procurement did not conform to Uniform Guidance for 2 of 3 vendors tested in our sample.
Cause
The District did not follow Federal Funds Procurement policy.
Effect
Obtaining price or rate quotations from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services.
Repeat Finding
Yes – 2022-005Recommendation
We recommend the District review procurement policies and establish a procurement process in order to ensure this policy is being followed.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Suspension and Debarment
Type of Finding
Significant deficiency in internal control over compliance
Condition
District did not document procedures for verification of suspension and debarment of vendors.
Questioned Costs
None.
Criteria
2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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.
Context
The District did not review 1 of 2 vendors tested in our sample to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause
The District does not have a policy or procedure in place to check if a vendor is debarred or suspended.
Effect
The District could contract with a vendor that has been suspended or debarred from receiving federal funds.Repeat Finding
No
Recommendation
We recommend the District use sam.gov listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Suspension and Debarment
Type of Finding
Significant deficiency in internal control over compliance
Condition
District did not document procedures for verification of suspension and debarment of vendors.
Questioned Costs
None.
Criteria
2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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.
Context
The District did not review 1 of 2 vendors tested in our sample to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause
The District does not have a policy or procedure in place to check if a vendor is debarred or suspended.
Effect
The District could contract with a vendor that has been suspended or debarred from receiving federal funds.Repeat Finding
No
Recommendation
We recommend the District use sam.gov listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Special Tests and Provisions – Verification of Applications
Type of Finding
Material weakness in internal control over compliance, Qualification
Criteria
The District is required to verify and support with documentation 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 as of October 1 and completed by November 15.
Condition
The District did not retain workpapers to support that the special tests and provision requirement to perform verification of free and reduced price applications was completed.
Context
The District has limited employees and does not have adequate segregation of duties over the grant management process to ensure that the documentation to support the verification process was retained.
Cause
The District did not retain documentation and other information to support their procedures over the compliance requirements of the program.
Effect
The District may have households that were not eligible for the status based on the documentation and other information obtained through the verification process.
Repeat Finding
Yes - 2022-004
Recommendation
We recommend the District establish procedures and controls over the retention of verification documentation and other information obtained through the verification process.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Special Tests and Provisions – Verification of Applications
Type of Finding
Material weakness in internal control over compliance, Qualification
Criteria
The District is required to verify and support with documentation 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 as of October 1 and completed by November 15.
Condition
The District did not retain workpapers to support that the special tests and provision requirement to perform verification of free and reduced price applications was completed.
Context
The District has limited employees and does not have adequate segregation of duties over the grant management process to ensure that the documentation to support the verification process was retained.
Cause
The District did not retain documentation and other information to support their procedures over the compliance requirements of the program.
Effect
The District may have households that were not eligible for the status based on the documentation and other information obtained through the verification process.
Repeat Finding
Yes - 2022-004
Recommendation
We recommend the District establish procedures and controls over the retention of verification documentation and other information obtained through the verification process.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Procurement
Type of Finding
Significant deficiency in internal control over compliance
Criteria
2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors.
Condition
During our testing of procurement transactions of the program we noted that 2 of 3 vendors selected were not supported by any price or rate quotations to ensure the District is prudent with the monies used towards the program.
Questioned Costs
None.
Context
The District's procurement did not conform to Uniform Guidance for 2 of 3 vendors tested in our sample.
Cause
The District did not follow Federal Funds Procurement policy.
Effect
Obtaining price or rate quotations from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services.
Repeat Finding
Yes – 2022-005Recommendation
We recommend the District review procurement policies and establish a procurement process in order to ensure this policy is being followed.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Procurement
Type of Finding
Significant deficiency in internal control over compliance
Criteria
2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors.
Condition
During our testing of procurement transactions of the program we noted that 2 of 3 vendors selected were not supported by any price or rate quotations to ensure the District is prudent with the monies used towards the program.
Questioned Costs
None.
Context
The District's procurement did not conform to Uniform Guidance for 2 of 3 vendors tested in our sample.
Cause
The District did not follow Federal Funds Procurement policy.
Effect
Obtaining price or rate quotations from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services.
Repeat Finding
Yes – 2022-005Recommendation
We recommend the District review procurement policies and establish a procurement process in order to ensure this policy is being followed.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Suspension and Debarment
Type of Finding
Significant deficiency in internal control over compliance
Condition
District did not document procedures for verification of suspension and debarment of vendors.
Questioned Costs
None.
Criteria
2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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.
Context
The District did not review 1 of 2 vendors tested in our sample to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause
The District does not have a policy or procedure in place to check if a vendor is debarred or suspended.
Effect
The District could contract with a vendor that has been suspended or debarred from receiving federal funds.Repeat Finding
No
Recommendation
We recommend the District use sam.gov listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements.
Views of Responsible Officials
There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Suspension and Debarment
Type of Finding
Significant deficiency in internal control over compliance
Condition
District did not document procedures for verification of suspension and debarment of vendors.
Questioned Costs
None.
Criteria
2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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.
Context
The District did not review 1 of 2 vendors tested in our sample to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause
The District does not have a policy or procedure in place to check if a vendor is debarred or suspended.
Effect
The District could contract with a vendor that has been suspended or debarred from receiving federal funds.Repeat Finding
No
Recommendation
We recommend the District use sam.gov listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements.
Views of Responsible Officials
There is no disagreement with the audit finding.