Audit 257573

Finding 2022-001 Assistance Listing Number: 93.870 Federal Program: Maternal, Infant, and Early Childhood Home Visiting Grant Name of Federal Agency: Department of Health and Human Services Name of Pass-Through Entity: Wisconsin Department of Children and Families Criteria or Specific Requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at Title 2 U.S. Code of Federal Regulations (CFR) SECTIONS 200.318 THROUGH 200.236. 2 CFR section 200.318(a) indicates the non-federal entity's documented procurement procedures must conform to the procurement standards identified in these sections. Condition: The Organization's documented procurement policies and procedures do not include certain procedures required by the procurement standards. Cause: The Organization does not have a process for reviewing its accounting policies and procedures manual on a regular basis to ensure documented procedures conform to the procurement standards. Effect or potential effect: Costs for purchases subject to the procurement standards could be disallowed if appropriate procedures are not followed. Repeat finding: No Recommendation: The Organization's procurement procedures should be reviewed and updated as needed to confirm to the procurement standards. The Organization's policies and procedures should also be reviewed and approved annually by the board of directors and management to incorporate changes to laws and regulations and internal procedures. Views of responsible officials: Easterseals Southeast Wisconsin has a policy which clearly outlines approval authorities. While we follow that policy properly, we understand that the policy lacks some elements required by the Uniform Guidance. None of our purchases made during the year under audit would have violated Uniform Guidance, but we are committed to compliance and therefore have already started to draft policies which will adhere to Uniform Guidance. We will finalize, communicate, and follow our updated Policies and Procedures to ensure that Uniform Guidance is followed and to resolve the finding from this audit.

Finding 2022-001 Assistance Listing Number: 93.870 Federal Program: Maternal, Infant, and Early Childhood Home Visiting Grant Name of Federal Agency: Department of Health and Human Services Name of Pass-Through Entity: Wisconsin Department of Children and Families Criteria or Specific Requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at Title 2 U.S. Code of Federal Regulations (CFR) SECTIONS 200.318 THROUGH 200.236. 2 CFR section 200.318(a) indicates the non-federal entity's documented procurement procedures must conform to the procurement standards identified in these sections. Condition: The Organization's documented procurement policies and procedures do not include certain procedures required by the procurement standards. Cause: The Organization does not have a process for reviewing its accounting policies and procedures manual on a regular basis to ensure documented procedures conform to the procurement standards. Effect or potential effect: Costs for purchases subject to the procurement standards could be disallowed if appropriate procedures are not followed. Repeat finding: No Recommendation: The Organization's procurement procedures should be reviewed and updated as needed to confirm to the procurement standards. The Organization's policies and procedures should also be reviewed and approved annually by the board of directors and management to incorporate changes to laws and regulations and internal procedures. Views of responsible officials: Easterseals Southeast Wisconsin has a policy which clearly outlines approval authorities. While we follow that policy properly, we understand that the policy lacks some elements required by the Uniform Guidance. None of our purchases made during the year under audit would have violated Uniform Guidance, but we are committed to compliance and therefore have already started to draft policies which will adhere to Uniform Guidance. We will finalize, communicate, and follow our updated Policies and Procedures to ensure that Uniform Guidance is followed and to resolve the finding from this audit.