2023-004 Child Nutrition Suspension and Debarment
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Federal Award Identification Number and Year: Unknown
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-SB-546, 2023-371561-DPI-NSL-547
Award Period: 7/1/2022-6/30/23
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter
Criteria or Specific Requirement: 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.
Compliance Requirements: Suspension and Debarment.
Condition: The District's search for suspension and debarment was focused on common vendors that the District used often and consistently rather than all vendors that met the covered transaction requirements.
Questioned Costs: None.
Context: One out of the two vendors in our sample did not have any review completed by the District to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause: The District was unclear on when exactly certain transactions and vendors needed to be verified.
Effect: District could contract with a vendor that has been suspended or debarred from receiving federal funds.
Repeat Finding: No.
Recommendation: We recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 Child Nutrition Suspension and Debarment
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Federal Award Identification Number and Year: Unknown
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-SB-546, 2023-371561-DPI-NSL-547
Award Period: 7/1/2022-6/30/23
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter
Criteria or Specific Requirement: 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.
Compliance Requirements: Suspension and Debarment.
Condition: The District's search for suspension and debarment was focused on common vendors that the District used often and consistently rather than all vendors that met the covered transaction requirements.
Questioned Costs: None.
Context: One out of the two vendors in our sample did not have any review completed by the District to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause: The District was unclear on when exactly certain transactions and vendors needed to be verified.
Effect: District could contract with a vendor that has been suspended or debarred from receiving federal funds.
Repeat Finding: No.
Recommendation: We recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 Child Nutrition Suspension and Debarment
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Federal Award Identification Number and Year: Unknown
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-SB-546, 2023-371561-DPI-NSL-547
Award Period: 7/1/2022-6/30/23
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter
Criteria or Specific Requirement: 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.
Compliance Requirements: Suspension and Debarment.
Condition: The District's search for suspension and debarment was focused on common vendors that the District used often and consistently rather than all vendors that met the covered transaction requirements.
Questioned Costs: None.
Context: One out of the two vendors in our sample did not have any review completed by the District to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause: The District was unclear on when exactly certain transactions and vendors needed to be verified.
Effect: District could contract with a vendor that has been suspended or debarred from receiving federal funds.
Repeat Finding: No.
Recommendation: We recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 ESSER Segregation of Duties
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief
Assistance Listing Number: 84.425D, 84.425U
Federal Award Identification Number and Year: S425U210044
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-LETRS-165, 2023-371561-DPI-ESSERFII-163, 2023-371561-DPI-ESSERFIII-165
Award Period: 3/13/2020-9/30/2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction.
Compliance Requirements: Reporting.
Condition: The District Administrator and Bookkeeper collaborated in preparing the annual report. There was no review of the data entered into DPI's Wisegrants System by the bookkeeper by someone other than the preparer prior to submitting it. Accordingly, this does not allow for a proper segregation of duties for internal control purposes.
Questioned Costs: None.
Context: When reviewing the annual report, it was noted that the District Administrator and Bookkeeper collaborated in preparing the report, but no one reviewed report before submitting the document.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. In addition, this was a new report and the employee that normally reviews reports assisted the Bookkeeper in preparing the report instead.
Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties.
Repeat Finding: No.
Recommendation: We recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 ESSER Segregation of Duties
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief
Assistance Listing Number: 84.425D, 84.425U
Federal Award Identification Number and Year: S425U210044
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-LETRS-165, 2023-371561-DPI-ESSERFII-163, 2023-371561-DPI-ESSERFIII-165
Award Period: 3/13/2020-9/30/2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction.
Compliance Requirements: Reporting.
Condition: The District Administrator and Bookkeeper collaborated in preparing the annual report. There was no review of the data entered into DPI's Wisegrants System by the bookkeeper by someone other than the preparer prior to submitting it. Accordingly, this does not allow for a proper segregation of duties for internal control purposes.
Questioned Costs: None.
Context: When reviewing the annual report, it was noted that the District Administrator and Bookkeeper collaborated in preparing the report, but no one reviewed report before submitting the document.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. In addition, this was a new report and the employee that normally reviews reports assisted the Bookkeeper in preparing the report instead.
Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties.
Repeat Finding: No.
Recommendation: We recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 ESSER Segregation of Duties
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief
Assistance Listing Number: 84.425D, 84.425U
Federal Award Identification Number and Year: S425U210044
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-LETRS-165, 2023-371561-DPI-ESSERFII-163, 2023-371561-DPI-ESSERFIII-165
Award Period: 3/13/2020-9/30/2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction.
Compliance Requirements: Reporting.
Condition: The District Administrator and Bookkeeper collaborated in preparing the annual report. There was no review of the data entered into DPI's Wisegrants System by the bookkeeper by someone other than the preparer prior to submitting it. Accordingly, this does not allow for a proper segregation of duties for internal control purposes.
Questioned Costs: None.
Context: When reviewing the annual report, it was noted that the District Administrator and Bookkeeper collaborated in preparing the report, but no one reviewed report before submitting the document.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. In addition, this was a new report and the employee that normally reviews reports assisted the Bookkeeper in preparing the report instead.
Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties.
Repeat Finding: No.
Recommendation: We recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 Child Nutrition Suspension and Debarment
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Federal Award Identification Number and Year: Unknown
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-SB-546, 2023-371561-DPI-NSL-547
Award Period: 7/1/2022-6/30/23
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter
Criteria or Specific Requirement: 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.
Compliance Requirements: Suspension and Debarment.
Condition: The District's search for suspension and debarment was focused on common vendors that the District used often and consistently rather than all vendors that met the covered transaction requirements.
Questioned Costs: None.
Context: One out of the two vendors in our sample did not have any review completed by the District to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause: The District was unclear on when exactly certain transactions and vendors needed to be verified.
Effect: District could contract with a vendor that has been suspended or debarred from receiving federal funds.
Repeat Finding: No.
Recommendation: We recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 Child Nutrition Suspension and Debarment
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Federal Award Identification Number and Year: Unknown
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-SB-546, 2023-371561-DPI-NSL-547
Award Period: 7/1/2022-6/30/23
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter
Criteria or Specific Requirement: 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.
Compliance Requirements: Suspension and Debarment.
Condition: The District's search for suspension and debarment was focused on common vendors that the District used often and consistently rather than all vendors that met the covered transaction requirements.
Questioned Costs: None.
Context: One out of the two vendors in our sample did not have any review completed by the District to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause: The District was unclear on when exactly certain transactions and vendors needed to be verified.
Effect: District could contract with a vendor that has been suspended or debarred from receiving federal funds.
Repeat Finding: No.
Recommendation: We recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 Child Nutrition Suspension and Debarment
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Federal Award Identification Number and Year: Unknown
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-SB-546, 2023-371561-DPI-NSL-547
Award Period: 7/1/2022-6/30/23
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter
Criteria or Specific Requirement: 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.
Compliance Requirements: Suspension and Debarment.
Condition: The District's search for suspension and debarment was focused on common vendors that the District used often and consistently rather than all vendors that met the covered transaction requirements.
Questioned Costs: None.
Context: One out of the two vendors in our sample did not have any review completed by the District to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause: The District was unclear on when exactly certain transactions and vendors needed to be verified.
Effect: District could contract with a vendor that has been suspended or debarred from receiving federal funds.
Repeat Finding: No.
Recommendation: We recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 ESSER Segregation of Duties
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief
Assistance Listing Number: 84.425D, 84.425U
Federal Award Identification Number and Year: S425U210044
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-LETRS-165, 2023-371561-DPI-ESSERFII-163, 2023-371561-DPI-ESSERFIII-165
Award Period: 3/13/2020-9/30/2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction.
Compliance Requirements: Reporting.
Condition: The District Administrator and Bookkeeper collaborated in preparing the annual report. There was no review of the data entered into DPI's Wisegrants System by the bookkeeper by someone other than the preparer prior to submitting it. Accordingly, this does not allow for a proper segregation of duties for internal control purposes.
Questioned Costs: None.
Context: When reviewing the annual report, it was noted that the District Administrator and Bookkeeper collaborated in preparing the report, but no one reviewed report before submitting the document.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. In addition, this was a new report and the employee that normally reviews reports assisted the Bookkeeper in preparing the report instead.
Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties.
Repeat Finding: No.
Recommendation: We recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 ESSER Segregation of Duties
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief
Assistance Listing Number: 84.425D, 84.425U
Federal Award Identification Number and Year: S425U210044
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-LETRS-165, 2023-371561-DPI-ESSERFII-163, 2023-371561-DPI-ESSERFIII-165
Award Period: 3/13/2020-9/30/2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction.
Compliance Requirements: Reporting.
Condition: The District Administrator and Bookkeeper collaborated in preparing the annual report. There was no review of the data entered into DPI's Wisegrants System by the bookkeeper by someone other than the preparer prior to submitting it. Accordingly, this does not allow for a proper segregation of duties for internal control purposes.
Questioned Costs: None.
Context: When reviewing the annual report, it was noted that the District Administrator and Bookkeeper collaborated in preparing the report, but no one reviewed report before submitting the document.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. In addition, this was a new report and the employee that normally reviews reports assisted the Bookkeeper in preparing the report instead.
Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties.
Repeat Finding: No.
Recommendation: We recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 ESSER Segregation of Duties
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief
Assistance Listing Number: 84.425D, 84.425U
Federal Award Identification Number and Year: S425U210044
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-371561-DPI-LETRS-165, 2023-371561-DPI-ESSERFII-163, 2023-371561-DPI-ESSERFIII-165
Award Period: 3/13/2020-9/30/2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction.
Compliance Requirements: Reporting.
Condition: The District Administrator and Bookkeeper collaborated in preparing the annual report. There was no review of the data entered into DPI's Wisegrants System by the bookkeeper by someone other than the preparer prior to submitting it. Accordingly, this does not allow for a proper segregation of duties for internal control purposes.
Questioned Costs: None.
Context: When reviewing the annual report, it was noted that the District Administrator and Bookkeeper collaborated in preparing the report, but no one reviewed report before submitting the document.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. In addition, this was a new report and the employee that normally reviews reports assisted the Bookkeeper in preparing the report instead.
Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties.
Repeat Finding: No.
Recommendation: We recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports.
Views of Responsible Officials: There is no disagreement with the audit finding.