Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Education Stabilization Fund Equipment/Real Property Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund and Governor's Emergency Education Relief Fund Assistance Listing Number: 84.425C and 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163, 2021-102394-DPIGEERF-162, 2021-102394-DPIESSERF-160 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 2 CFR Section 200.131(d) states (1) property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: The District's controls identified and tracked assets that were paid for by grant dollars, however there needs to be improvements in the documentation of those controls. Questioned Costs: None. Context: While performing audit procedures, it was noted that the District did not have policies in place to ensure documentation of the District?s controls classifying and retaining information about capital asset purchases with federal funds for both assets in our sample. Cause: The District was not aware of the compliance requirements related to equipment and real property purchased with federal funding by the District. Effect: Equipment or real property purchased with federal funds may not have properly maintained property records and upon disposition of the asset the District may have failed to provide information and funds back to the federal government. Repeat Finding: No Recommendation: We recommended that the District implement proper documentation of controls over maintaining property records for equipment and real property purchased with federal funds and ensure documentation of a physical inventory of capital assets is completed at least every two years. Views of Responsible Officials: There is no disagreement with the audit finding.
Education Stabilization Fund Wage Rate Requirements Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter Criteria or Specific Requirement: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The District had 2 construction projects funded by ESSER during 2021-22. The District is responsible for ensuring the contractor provides the appropriate certified payrolls and reviewing them to ensure the prevailing wage rates are being met or exceeded. The documented review of the certified payrolls did not occur. When the District had a construction manager for one of the projects, the District did not implement controls to monitor the construction management company to ensure this compliance requirement was met. Questioned Costs: $14,420. Context: For one of the projects, the District did not have a signed contract that included all required prevailing wage components. The District did not obtain the appropriate certified payrolls and did not document any review of the certified payrolls ensuring appropriate wage rates were being charged for the project. It was noted that the District's construction manager for the other project did obtain and review the appropriate certified payrolls; however, the District did not implement controls to monitor the construction manager to ensure this compliance requirement was met. Cause: The District was not aware of the Davis Bacon Act and the compliance requirements surrounding it. Effect: The District could pay vendors that are not in compliance with the wage rate requirements (Davis Bacon Act). Repeat Finding: No Recommendation: We recommended that the District implement controls to ensure construction contracts include the proper wording and implement controls to ensure certified payrolls are received and reviewed. We also recommend the district implement controls for monitoring third-party contractors when the contractors are responsible for compliance requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
Education Stabilization Fund Equipment/Real Property Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund and Governor's Emergency Education Relief Fund Assistance Listing Number: 84.425C and 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163, 2021-102394-DPIGEERF-162, 2021-102394-DPIESSERF-160 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 2 CFR Section 200.131(d) states (1) property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: The District's controls identified and tracked assets that were paid for by grant dollars, however there needs to be improvements in the documentation of those controls. Questioned Costs: None. Context: While performing audit procedures, it was noted that the District did not have policies in place to ensure documentation of the District?s controls classifying and retaining information about capital asset purchases with federal funds for both assets in our sample. Cause: The District was not aware of the compliance requirements related to equipment and real property purchased with federal funding by the District. Effect: Equipment or real property purchased with federal funds may not have properly maintained property records and upon disposition of the asset the District may have failed to provide information and funds back to the federal government. Repeat Finding: No Recommendation: We recommended that the District implement proper documentation of controls over maintaining property records for equipment and real property purchased with federal funds and ensure documentation of a physical inventory of capital assets is completed at least every two years. Views of Responsible Officials: There is no disagreement with the audit finding.
Education Stabilization Fund Equipment/Real Property Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund and Governor's Emergency Education Relief Fund Assistance Listing Number: 84.425C and 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163, 2021-102394-DPIGEERF-162, 2021-102394-DPIESSERF-160 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 2 CFR Section 200.131(d) states (1) property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: The District's controls identified and tracked assets that were paid for by grant dollars, however there needs to be improvements in the documentation of those controls. Questioned Costs: None. Context: While performing audit procedures, it was noted that the District did not have policies in place to ensure documentation of the District?s controls classifying and retaining information about capital asset purchases with federal funds for both assets in our sample. Cause: The District was not aware of the compliance requirements related to equipment and real property purchased with federal funding by the District. Effect: Equipment or real property purchased with federal funds may not have properly maintained property records and upon disposition of the asset the District may have failed to provide information and funds back to the federal government. Repeat Finding: No Recommendation: We recommended that the District implement proper documentation of controls over maintaining property records for equipment and real property purchased with federal funds and ensure documentation of a physical inventory of capital assets is completed at least every two years. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance. 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 is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires purchases and contracts to be authorized prior to Board approval of monthly expenditures. Questioned Costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files and document approval of contracts as required by District policy. It was also noted that neither of the two procurement transactions tested formally documented the approvals over the contract before purchases were initiated by someone within the District. The District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample however the vendor was determined to not be on the suspended and debarred list. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts 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 ensure compliance. 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. Views of Reasonable Officials: District does not have any disagreement with the audit finding.
Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 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. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.
Education Stabilization Fund Equipment/Real Property Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund and Governor's Emergency Education Relief Fund Assistance Listing Number: 84.425C and 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163, 2021-102394-DPIGEERF-162, 2021-102394-DPIESSERF-160 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 2 CFR Section 200.131(d) states (1) property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: The District's controls identified and tracked assets that were paid for by grant dollars, however there needs to be improvements in the documentation of those controls. Questioned Costs: None. Context: While performing audit procedures, it was noted that the District did not have policies in place to ensure documentation of the District?s controls classifying and retaining information about capital asset purchases with federal funds for both assets in our sample. Cause: The District was not aware of the compliance requirements related to equipment and real property purchased with federal funding by the District. Effect: Equipment or real property purchased with federal funds may not have properly maintained property records and upon disposition of the asset the District may have failed to provide information and funds back to the federal government. Repeat Finding: No Recommendation: We recommended that the District implement proper documentation of controls over maintaining property records for equipment and real property purchased with federal funds and ensure documentation of a physical inventory of capital assets is completed at least every two years. Views of Responsible Officials: There is no disagreement with the audit finding.
Education Stabilization Fund Wage Rate Requirements Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter Criteria or Specific Requirement: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The District had 2 construction projects funded by ESSER during 2021-22. The District is responsible for ensuring the contractor provides the appropriate certified payrolls and reviewing them to ensure the prevailing wage rates are being met or exceeded. The documented review of the certified payrolls did not occur. When the District had a construction manager for one of the projects, the District did not implement controls to monitor the construction management company to ensure this compliance requirement was met. Questioned Costs: $14,420. Context: For one of the projects, the District did not have a signed contract that included all required prevailing wage components. The District did not obtain the appropriate certified payrolls and did not document any review of the certified payrolls ensuring appropriate wage rates were being charged for the project. It was noted that the District's construction manager for the other project did obtain and review the appropriate certified payrolls; however, the District did not implement controls to monitor the construction manager to ensure this compliance requirement was met. Cause: The District was not aware of the Davis Bacon Act and the compliance requirements surrounding it. Effect: The District could pay vendors that are not in compliance with the wage rate requirements (Davis Bacon Act). Repeat Finding: No Recommendation: We recommended that the District implement controls to ensure construction contracts include the proper wording and implement controls to ensure certified payrolls are received and reviewed. We also recommend the district implement controls for monitoring third-party contractors when the contractors are responsible for compliance requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
Education Stabilization Fund Equipment/Real Property Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund and Governor's Emergency Education Relief Fund Assistance Listing Number: 84.425C and 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163, 2021-102394-DPIGEERF-162, 2021-102394-DPIESSERF-160 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 2 CFR Section 200.131(d) states (1) property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: The District's controls identified and tracked assets that were paid for by grant dollars, however there needs to be improvements in the documentation of those controls. Questioned Costs: None. Context: While performing audit procedures, it was noted that the District did not have policies in place to ensure documentation of the District?s controls classifying and retaining information about capital asset purchases with federal funds for both assets in our sample. Cause: The District was not aware of the compliance requirements related to equipment and real property purchased with federal funding by the District. Effect: Equipment or real property purchased with federal funds may not have properly maintained property records and upon disposition of the asset the District may have failed to provide information and funds back to the federal government. Repeat Finding: No Recommendation: We recommended that the District implement proper documentation of controls over maintaining property records for equipment and real property purchased with federal funds and ensure documentation of a physical inventory of capital assets is completed at least every two years. Views of Responsible Officials: There is no disagreement with the audit finding.
Education Stabilization Fund Equipment/Real Property Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund and Governor's Emergency Education Relief Fund Assistance Listing Number: 84.425C and 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163, 2021-102394-DPIGEERF-162, 2021-102394-DPIESSERF-160 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 2 CFR Section 200.131(d) states (1) property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: The District's controls identified and tracked assets that were paid for by grant dollars, however there needs to be improvements in the documentation of those controls. Questioned Costs: None. Context: While performing audit procedures, it was noted that the District did not have policies in place to ensure documentation of the District?s controls classifying and retaining information about capital asset purchases with federal funds for both assets in our sample. Cause: The District was not aware of the compliance requirements related to equipment and real property purchased with federal funding by the District. Effect: Equipment or real property purchased with federal funds may not have properly maintained property records and upon disposition of the asset the District may have failed to provide information and funds back to the federal government. Repeat Finding: No Recommendation: We recommended that the District implement proper documentation of controls over maintaining property records for equipment and real property purchased with federal funds and ensure documentation of a physical inventory of capital assets is completed at least every two years. Views of Responsible Officials: There is no disagreement with the audit finding.