FAC Explorer

Audit 21088

FY End
2022-06-30
Total Expended
$5.93M
Findings
10
Programs
12
Organization: School District of Greenfield (WI)
Year: 2022 Accepted: 2023-01-02
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
16613 2022-002 Significant Deficiency - I
16614 2022-002 Significant Deficiency - I
16615 2022-002 Significant Deficiency - I
16616 2022-002 Significant Deficiency - I
16617 2022-002 Significant Deficiency - I
593055 2022-002 Significant Deficiency - I
593056 2022-002 Significant Deficiency - I
593057 2022-002 Significant Deficiency - I
593058 2022-002 Significant Deficiency - I
593059 2022-002 Significant Deficiency - I

Programs

ALN Program Spent Major Findings
84.010 Title I Grants to Local Educational Agencies $553,699 - 0
93.778 Medical Assistance Program $353,950 - 0
10.553 School Breakfast Program $300,170 Yes 0
32.009 Emergency Connectivity Fund Program $222,292 - 0
10.555 National School Lunch Program $181,648 Yes 0
84.367 Improving Teacher Quality State Grants $143,265 - 0
84.027 Special Education_grants to States $129,352 Yes 1
10.559 Summer Food Service Program for Children $79,505 Yes 0
84.365 English Language Acquisition State Grants $37,650 - 0
84.424 Student Support and Academic Enrichment Program $35,366 - 0
84.173 Special Education_preschool Grants $18,056 Yes 1
84.425 Education Stabilization Fund $7,377 Yes 0

Contacts

Name Title Type
G9WLPLUNZ8M7 Danielle Gross Auditee
4148552038 Bryan Grunewald Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the District's 2022 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and State Single Audit Guidelines, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year's ending balances. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying schedules of expenditures of federal and state awards for the School District of Greenfield are presented n accordance with the requirements of Title 2 U.S. code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and the State Single Audit Guidelines issued by the Wisconsin Department of Administration. The schedules of expenditures of federal and state awards include all federal and state awards of the District. Because the schedules present only a selected portion of the operations of the District, it is not intended to and does not present the financial position or changes in net position of the District.
Title: SPECIAL EDUCATION AND SCHOOL AGE PARENTS PROGRAM Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the District's 2022 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and State Single Audit Guidelines, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year's ending balances. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The 2021-2022 eligible costs under the State Special Education Program as reported by the District are $6,208,816. Compiled information required by compliance requirement 1-1 of the Special Education Audit Program was reported to the Wisconsin Department of Public Instruction.
Title: FOOD DISTRIBUTION Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the District's 2022 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and State Single Audit Guidelines, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year's ending balances. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Nonmonetary assistance is reported in the schedule of expenditures of federal awards at the fair market value of the commodities received and disbursed.
Title: OVERSIGHT AGENCIES Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the District's 2022 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and State Single Audit Guidelines, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year's ending balances. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The federal and state oversight agencies for the District are as follows: Federal - U.S. Department of Education; State - Wisconsin Department of Public Instruction
Title: PASS-THROUGH ENTITIES Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the District's 2022 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and State Single Audit Guidelines, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year's ending balances. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Federal awards have been passed through the following entities: WI DHS - Wisconsin Department of Health Services; WI DPI - Wisconsin Department of Public Instruction

Finding Details

Finding 2022-002
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Finding 2022-002
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Finding 2022-002
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Finding 2022-002
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Finding 2022-002
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Finding 2022-002
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Finding 2022-002
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Finding 2022-002
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Finding 2022-002
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.
Finding 2022-002
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.