FAC Explorer

Audit 13713

FY End
2023-06-30
Total Expended
$50.45M
Findings
8
Programs
18
Organization: Green Bay Area Public Schools (WI)
Year: 2023 Accepted: 2024-01-25
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
10087 2023-002 Significant Deficiency - I
10088 2023-002 Significant Deficiency - I
10089 2023-002 Significant Deficiency - I
10090 2023-002 Significant Deficiency - I
586529 2023-002 Significant Deficiency - I
586530 2023-002 Significant Deficiency - I
586531 2023-002 Significant Deficiency - I
586532 2023-002 Significant Deficiency - I

Programs

ALN Program Spent Major Findings
93.600 Head Start $4.37M - 0
93.778 Medical Assistance Program $3.97M Yes 0
10.553 School Breakfast Program $2.10M - 0
10.555 National School Lunch Program $1.08M - 0
84.367 Improving Teacher Quality State Grants $978,070 - 0
84.287 Twenty-First Century Community Learning Centers $727,163 - 0
84.365 English Language Acquisition State Grants $639,680 - 0
10.558 Child and Adult Care Food Program $636,034 - 0
84.424 Student Support and Academic Enrichment Program $630,023 - 0
10.559 Summer Food Service Program for Children $411,285 - 0
84.060 Indian Education_grants to Local Educational Agencies $297,293 - 0
84.048 Career and Technical Education -- Basic Grants to States $220,186 - 0
84.173 Special Education_preschool Grants $178,078 Yes 1
84.425 Education Stabilization Fund $175,458 Yes 0
84.196 Education for Homeless Children and Youth $114,584 - 0
84.010 Title I Grants to Local Educational Agencies $99,477 - 0
84.027 Special Education_grants to States $5,000 Yes 1
84.184 Safe and Drug-Free Schools and Communities_national Programs $2,797 - 0

Contacts

Name Title Type
KTMFQB98UHH5 Angela Roble Auditee
9204482208 Jon Trautman, CPA Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the District’s 2023 fund financial statements. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year’s ending balances. Such expenditures are recognized following the cost principals contained in the Uniform Guidance and State Single Audit Guidelines, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the schedules of expenditures of federal and state awards represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The District has not elected to charge a de minimis rate of 10% of modified total costs. The accompanying schedules of expenditures of federal and state awards for the Green Bay Area Public School District (the District) are presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and the State Single Audit Guidelines issued by the Wisconsin Department of Administration. The schedules of expenditures of federal and state awards include all federal and state awards of the District. Because the schedules present only a selected portion of the operations of the District, it is not intended to and does not present the financial position, changes in net position, or cash flows of the District.
Title: FOOD DISTRIBUTION Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the District’s 2023 fund financial statements. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year’s ending balances. Such expenditures are recognized following the cost principals contained in the Uniform Guidance and State Single Audit Guidelines, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the schedules of expenditures of federal and state awards represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The District has not elected to charge a de minimis rate of 10% of modified total costs. Nonmonetary assistance is reported in the schedule of expenditures of federal awards at the fair market value of the commodities received and disbursed.
Title: OVERSIGHT AGENCIES Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the District’s 2023 fund financial statements. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year’s ending balances. Such expenditures are recognized following the cost principals contained in the Uniform Guidance and State Single Audit Guidelines, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the schedules of expenditures of federal and state awards represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The District has not elected to charge a de minimis rate of 10% of modified total costs. The federal and state oversight agencies for the District are as follows: Federal – U.S. Department of Health and Human Services State – Wisconsin Department of Public Instruction
Title: PASS-THROUGH ENTITIES Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the District’s 2023 fund financial statements. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year’s ending balances. Such expenditures are recognized following the cost principals contained in the Uniform Guidance and State Single Audit Guidelines, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the schedules of expenditures of federal and state awards represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The District has not elected to charge a de minimis rate of 10% of modified total costs. Federal awards have been passed through the following entities: WI DHS – Wisconsin Department of Health Services WI DPI – Wisconsin Department of Public Instruction CESA #12 – Cooperative Educational Services Agency #12
Title: DONATED SERVICES Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the District’s 2023 fund financial statements. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year’s ending balances. Such expenditures are recognized following the cost principals contained in the Uniform Guidance and State Single Audit Guidelines, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the schedules of expenditures of federal and state awards represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The District has not elected to charge a de minimis rate of 10% of modified total costs. The District receives an undeterminable amount of donated services from a variety of unpaid volunteers assisting the Head Start program. Therefore, no amounts have been recorded in the schedule of expenditures of federal awards.

Finding Details

Finding 2023-002
Federal Agency: US Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220064, H173A220070 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-052289-DPI-FLOW-341, 2023-052289-DPI-WCCA-342, Unknown, 2023-052289-DPI-PRESCH-347 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 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. Condition: The District has a policy to maintain documentation of the procurement process for any transaction, and to verify suspension and debarment status for the transactions over $25,000 related to federal grants but they have not implemented formal internal controls to ensure that they did follow the procurement policy and check suspension and debarment. Questioned Costs: None Context: The District did not maintain documentation for the reasoning that two of the seven procurement transactions in our sample (repeat contracts) were designated as a sole source. The District did not verify suspension and debarment for two of the five vendors (with repeat contracts) prior to signing the contract applicable for the current year. Cause: The District does not maintain a listing of the repeat contracts to determine if it they are currently within the term of the original contract, have an addendum to the length of term on the original contract, or are in new procurement for the same product from a vendor that was previously designated as a sole source. Therefore, the District could not easily provide a listing of procurements that are applicable to the current year, provide documentation of the reasons to utilize these vendors and since they were long term vendors, the District was not aware they needed to be rechecked for suspension and debarment every time a new contract was entered into. Additionally, individual invoices under these repeat contracts do not require a purchase order. Therefore, they did not go through the procurement department to verify the procurement process was performed and properly documented, and the suspension and debarment was included on the contract. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure the proper procurement method was followed and procurement history is documented. We also 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. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-002
Federal Agency: US Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220064, H173A220070 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-052289-DPI-FLOW-341, 2023-052289-DPI-WCCA-342, Unknown, 2023-052289-DPI-PRESCH-347 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 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. Condition: The District has a policy to maintain documentation of the procurement process for any transaction, and to verify suspension and debarment status for the transactions over $25,000 related to federal grants but they have not implemented formal internal controls to ensure that they did follow the procurement policy and check suspension and debarment. Questioned Costs: None Context: The District did not maintain documentation for the reasoning that two of the seven procurement transactions in our sample (repeat contracts) were designated as a sole source. The District did not verify suspension and debarment for two of the five vendors (with repeat contracts) prior to signing the contract applicable for the current year. Cause: The District does not maintain a listing of the repeat contracts to determine if it they are currently within the term of the original contract, have an addendum to the length of term on the original contract, or are in new procurement for the same product from a vendor that was previously designated as a sole source. Therefore, the District could not easily provide a listing of procurements that are applicable to the current year, provide documentation of the reasons to utilize these vendors and since they were long term vendors, the District was not aware they needed to be rechecked for suspension and debarment every time a new contract was entered into. Additionally, individual invoices under these repeat contracts do not require a purchase order. Therefore, they did not go through the procurement department to verify the procurement process was performed and properly documented, and the suspension and debarment was included on the contract. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure the proper procurement method was followed and procurement history is documented. We also 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. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-002
Federal Agency: US Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220064, H173A220070 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-052289-DPI-FLOW-341, 2023-052289-DPI-WCCA-342, Unknown, 2023-052289-DPI-PRESCH-347 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 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. Condition: The District has a policy to maintain documentation of the procurement process for any transaction, and to verify suspension and debarment status for the transactions over $25,000 related to federal grants but they have not implemented formal internal controls to ensure that they did follow the procurement policy and check suspension and debarment. Questioned Costs: None Context: The District did not maintain documentation for the reasoning that two of the seven procurement transactions in our sample (repeat contracts) were designated as a sole source. The District did not verify suspension and debarment for two of the five vendors (with repeat contracts) prior to signing the contract applicable for the current year. Cause: The District does not maintain a listing of the repeat contracts to determine if it they are currently within the term of the original contract, have an addendum to the length of term on the original contract, or are in new procurement for the same product from a vendor that was previously designated as a sole source. Therefore, the District could not easily provide a listing of procurements that are applicable to the current year, provide documentation of the reasons to utilize these vendors and since they were long term vendors, the District was not aware they needed to be rechecked for suspension and debarment every time a new contract was entered into. Additionally, individual invoices under these repeat contracts do not require a purchase order. Therefore, they did not go through the procurement department to verify the procurement process was performed and properly documented, and the suspension and debarment was included on the contract. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure the proper procurement method was followed and procurement history is documented. We also 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. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-002
Federal Agency: US Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220064, H173A220070 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-052289-DPI-FLOW-341, 2023-052289-DPI-WCCA-342, Unknown, 2023-052289-DPI-PRESCH-347 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 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. Condition: The District has a policy to maintain documentation of the procurement process for any transaction, and to verify suspension and debarment status for the transactions over $25,000 related to federal grants but they have not implemented formal internal controls to ensure that they did follow the procurement policy and check suspension and debarment. Questioned Costs: None Context: The District did not maintain documentation for the reasoning that two of the seven procurement transactions in our sample (repeat contracts) were designated as a sole source. The District did not verify suspension and debarment for two of the five vendors (with repeat contracts) prior to signing the contract applicable for the current year. Cause: The District does not maintain a listing of the repeat contracts to determine if it they are currently within the term of the original contract, have an addendum to the length of term on the original contract, or are in new procurement for the same product from a vendor that was previously designated as a sole source. Therefore, the District could not easily provide a listing of procurements that are applicable to the current year, provide documentation of the reasons to utilize these vendors and since they were long term vendors, the District was not aware they needed to be rechecked for suspension and debarment every time a new contract was entered into. Additionally, individual invoices under these repeat contracts do not require a purchase order. Therefore, they did not go through the procurement department to verify the procurement process was performed and properly documented, and the suspension and debarment was included on the contract. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure the proper procurement method was followed and procurement history is documented. We also 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. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-002
Federal Agency: US Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220064, H173A220070 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-052289-DPI-FLOW-341, 2023-052289-DPI-WCCA-342, Unknown, 2023-052289-DPI-PRESCH-347 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 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. Condition: The District has a policy to maintain documentation of the procurement process for any transaction, and to verify suspension and debarment status for the transactions over $25,000 related to federal grants but they have not implemented formal internal controls to ensure that they did follow the procurement policy and check suspension and debarment. Questioned Costs: None Context: The District did not maintain documentation for the reasoning that two of the seven procurement transactions in our sample (repeat contracts) were designated as a sole source. The District did not verify suspension and debarment for two of the five vendors (with repeat contracts) prior to signing the contract applicable for the current year. Cause: The District does not maintain a listing of the repeat contracts to determine if it they are currently within the term of the original contract, have an addendum to the length of term on the original contract, or are in new procurement for the same product from a vendor that was previously designated as a sole source. Therefore, the District could not easily provide a listing of procurements that are applicable to the current year, provide documentation of the reasons to utilize these vendors and since they were long term vendors, the District was not aware they needed to be rechecked for suspension and debarment every time a new contract was entered into. Additionally, individual invoices under these repeat contracts do not require a purchase order. Therefore, they did not go through the procurement department to verify the procurement process was performed and properly documented, and the suspension and debarment was included on the contract. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure the proper procurement method was followed and procurement history is documented. We also 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. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-002
Federal Agency: US Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220064, H173A220070 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-052289-DPI-FLOW-341, 2023-052289-DPI-WCCA-342, Unknown, 2023-052289-DPI-PRESCH-347 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 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. Condition: The District has a policy to maintain documentation of the procurement process for any transaction, and to verify suspension and debarment status for the transactions over $25,000 related to federal grants but they have not implemented formal internal controls to ensure that they did follow the procurement policy and check suspension and debarment. Questioned Costs: None Context: The District did not maintain documentation for the reasoning that two of the seven procurement transactions in our sample (repeat contracts) were designated as a sole source. The District did not verify suspension and debarment for two of the five vendors (with repeat contracts) prior to signing the contract applicable for the current year. Cause: The District does not maintain a listing of the repeat contracts to determine if it they are currently within the term of the original contract, have an addendum to the length of term on the original contract, or are in new procurement for the same product from a vendor that was previously designated as a sole source. Therefore, the District could not easily provide a listing of procurements that are applicable to the current year, provide documentation of the reasons to utilize these vendors and since they were long term vendors, the District was not aware they needed to be rechecked for suspension and debarment every time a new contract was entered into. Additionally, individual invoices under these repeat contracts do not require a purchase order. Therefore, they did not go through the procurement department to verify the procurement process was performed and properly documented, and the suspension and debarment was included on the contract. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure the proper procurement method was followed and procurement history is documented. We also 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. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-002
Federal Agency: US Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220064, H173A220070 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-052289-DPI-FLOW-341, 2023-052289-DPI-WCCA-342, Unknown, 2023-052289-DPI-PRESCH-347 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 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. Condition: The District has a policy to maintain documentation of the procurement process for any transaction, and to verify suspension and debarment status for the transactions over $25,000 related to federal grants but they have not implemented formal internal controls to ensure that they did follow the procurement policy and check suspension and debarment. Questioned Costs: None Context: The District did not maintain documentation for the reasoning that two of the seven procurement transactions in our sample (repeat contracts) were designated as a sole source. The District did not verify suspension and debarment for two of the five vendors (with repeat contracts) prior to signing the contract applicable for the current year. Cause: The District does not maintain a listing of the repeat contracts to determine if it they are currently within the term of the original contract, have an addendum to the length of term on the original contract, or are in new procurement for the same product from a vendor that was previously designated as a sole source. Therefore, the District could not easily provide a listing of procurements that are applicable to the current year, provide documentation of the reasons to utilize these vendors and since they were long term vendors, the District was not aware they needed to be rechecked for suspension and debarment every time a new contract was entered into. Additionally, individual invoices under these repeat contracts do not require a purchase order. Therefore, they did not go through the procurement department to verify the procurement process was performed and properly documented, and the suspension and debarment was included on the contract. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure the proper procurement method was followed and procurement history is documented. We also 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. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-002
Federal Agency: US Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220064, H173A220070 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-052289-DPI-FLOW-341, 2023-052289-DPI-WCCA-342, Unknown, 2023-052289-DPI-PRESCH-347 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 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. Condition: The District has a policy to maintain documentation of the procurement process for any transaction, and to verify suspension and debarment status for the transactions over $25,000 related to federal grants but they have not implemented formal internal controls to ensure that they did follow the procurement policy and check suspension and debarment. Questioned Costs: None Context: The District did not maintain documentation for the reasoning that two of the seven procurement transactions in our sample (repeat contracts) were designated as a sole source. The District did not verify suspension and debarment for two of the five vendors (with repeat contracts) prior to signing the contract applicable for the current year. Cause: The District does not maintain a listing of the repeat contracts to determine if it they are currently within the term of the original contract, have an addendum to the length of term on the original contract, or are in new procurement for the same product from a vendor that was previously designated as a sole source. Therefore, the District could not easily provide a listing of procurements that are applicable to the current year, provide documentation of the reasons to utilize these vendors and since they were long term vendors, the District was not aware they needed to be rechecked for suspension and debarment every time a new contract was entered into. Additionally, individual invoices under these repeat contracts do not require a purchase order. Therefore, they did not go through the procurement department to verify the procurement process was performed and properly documented, and the suspension and debarment was included on the contract. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure the proper procurement method was followed and procurement history is documented. We also 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. View of Responsible Officials: There is no disagreement with the audit finding.