Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirements Affected: Eligibility, Reporting, Special Tests and Provisions
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 procedure.
Condition: The claim forms submitted by the District are not reviewed and approved prior to submission. Eligibility and verification determinations are not reviewed and approved for accuracy or input into District software. Accordingly, this does not allow for proper segregation of duties for internal control purposes over reporting, eligibility, and special test compliance requirements.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations.
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 timely review.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirements Affected: Eligibility, Reporting, Special Tests and Provisions
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 procedure.
Condition: The claim forms submitted by the District are not reviewed and approved prior to submission. Eligibility and verification determinations are not reviewed and approved for accuracy or input into District software. Accordingly, this does not allow for proper segregation of duties for internal control purposes over reporting, eligibility, and special test compliance requirements.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations.
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 timely review.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirements Affected: Eligibility, Reporting, Special Tests and Provisions
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 procedure.
Condition: The claim forms submitted by the District are not reviewed and approved prior to submission. Eligibility and verification determinations are not reviewed and approved for accuracy or input into District software. Accordingly, this does not allow for proper segregation of duties for internal control purposes over reporting, eligibility, and special test compliance requirements.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations.
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 timely review.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirements Affected: Eligibility, Reporting, Special Tests and Provisions
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 procedure.
Condition: The claim forms submitted by the District are not reviewed and approved prior to submission. Eligibility and verification determinations are not reviewed and approved for accuracy or input into District software. Accordingly, this does not allow for proper segregation of duties for internal control purposes over reporting, eligibility, and special test compliance requirements.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations.
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 timely review.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement Affected: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Qualification
Criteria or specific requirement: 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). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment.
Questioned Costs: None
Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement
Effect: Obtaining price quotes or proposals 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. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement Affected: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Qualification
Criteria or specific requirement: 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). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment.
Questioned Costs: None
Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement
Effect: Obtaining price quotes or proposals 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. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement Affected: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Qualification
Criteria or specific requirement: 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). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment.
Questioned Costs: None
Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement
Effect: Obtaining price quotes or proposals 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. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement Affected: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Qualification
Criteria or specific requirement: 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). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment.
Questioned Costs: None
Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement
Effect: Obtaining price quotes or proposals 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. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirements Affected: Eligibility, Reporting, Special Tests and Provisions
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 procedure.
Condition: The claim forms submitted by the District are not reviewed and approved prior to submission. Eligibility and verification determinations are not reviewed and approved for accuracy or input into District software. Accordingly, this does not allow for proper segregation of duties for internal control purposes over reporting, eligibility, and special test compliance requirements.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations.
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 timely review.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirements Affected: Eligibility, Reporting, Special Tests and Provisions
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 procedure.
Condition: The claim forms submitted by the District are not reviewed and approved prior to submission. Eligibility and verification determinations are not reviewed and approved for accuracy or input into District software. Accordingly, this does not allow for proper segregation of duties for internal control purposes over reporting, eligibility, and special test compliance requirements.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations.
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 timely review.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirements Affected: Eligibility, Reporting, Special Tests and Provisions
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 procedure.
Condition: The claim forms submitted by the District are not reviewed and approved prior to submission. Eligibility and verification determinations are not reviewed and approved for accuracy or input into District software. Accordingly, this does not allow for proper segregation of duties for internal control purposes over reporting, eligibility, and special test compliance requirements.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations.
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 timely review.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirements Affected: Eligibility, Reporting, Special Tests and Provisions
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 procedure.
Condition: The claim forms submitted by the District are not reviewed and approved prior to submission. Eligibility and verification determinations are not reviewed and approved for accuracy or input into District software. Accordingly, this does not allow for proper segregation of duties for internal control purposes over reporting, eligibility, and special test compliance requirements.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations.
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 timely review.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement Affected: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Qualification
Criteria or specific requirement: 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). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment.
Questioned Costs: None
Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement
Effect: Obtaining price quotes or proposals 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. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement Affected: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Qualification
Criteria or specific requirement: 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). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment.
Questioned Costs: None
Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement
Effect: Obtaining price quotes or proposals 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. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement Affected: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Qualification
Criteria or specific requirement: 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). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment.
Questioned Costs: None
Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement
Effect: Obtaining price quotes or proposals 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. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.
Federal Agency: United States Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555, 10.556
Pass-Through Agency: Wisconsin Department of Instruction
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement Affected: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance, Qualification
Criteria or specific requirement: 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). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In addition during our testing of suspension and debarment, we identified one vendor contract that was entered into that did not include language related to suspension and debarment.
Questioned Costs: None
Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement
Effect: Obtaining price quotes or proposals 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. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies.
Views of Responsible Officials and Planned Corrective Action: No disagreement with finding.