2023-003 Child Nutrition Cluster - Segregation of Duties
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-375628-DPI-SB-546, 2023-375628-DPI-NSL-547
Award period: July 1, 2022 – June 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
• Other Matters
Compliance Requirements: Eligibility, Procurement, Reporting
Criteria or Specific Requirement: Uniform Guidance requires entities that expend federal funds are required to implement a system of internal controls to ensure that the entity remains in compliance with the requirements of the grant. 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: For activities related to Eligibility, Procurement, and Reporting, the District had not established procedures related to the documenting of the review and approval of the compliance requirements. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: During our testing we noted no review of the calculation of eligibility for the five applications submitted for testing, no review of the six monthly reports selected for testing, no approval on eight of the eleven micro-purchase transactions, and no documentation to support the price comparison for two of the three small purchase transactions selected for testing.
Cause: The District has not established policies to identify an individual to review the District’s compliance with the federal awards and how their review and approval is documented
Effect: Without an adequately designed system of internal controls over compliance, the District has an increased risk of non-compliance with the grant requirements. These risks include providing or denying benefits incorrectly, misreporting activities, or violating federal procurement requirements.
Repeat Finding: Repeat of Finding 2022-004 and 2022-005
Recommendation: We recommend that the District review the compliance requirements of the grant program and evaluate the currently assigned responsibilities by position to ensure that an adequate system of internal controls, including proper segregation of duties, exists.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 Child Nutrition Cluster - Segregation of Duties
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-375628-DPI-SB-546, 2023-375628-DPI-NSL-547
Award period: July 1, 2022 – June 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
• Other Matters
Compliance Requirements: Eligibility, Procurement, Reporting
Criteria or Specific Requirement: Uniform Guidance requires entities that expend federal funds are required to implement a system of internal controls to ensure that the entity remains in compliance with the requirements of the grant. 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: For activities related to Eligibility, Procurement, and Reporting, the District had not established procedures related to the documenting of the review and approval of the compliance requirements. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: During our testing we noted no review of the calculation of eligibility for the five applications submitted for testing, no review of the six monthly reports selected for testing, no approval on eight of the eleven micro-purchase transactions, and no documentation to support the price comparison for two of the three small purchase transactions selected for testing.
Cause: The District has not established policies to identify an individual to review the District’s compliance with the federal awards and how their review and approval is documented
Effect: Without an adequately designed system of internal controls over compliance, the District has an increased risk of non-compliance with the grant requirements. These risks include providing or denying benefits incorrectly, misreporting activities, or violating federal procurement requirements.
Repeat Finding: Repeat of Finding 2022-004 and 2022-005
Recommendation: We recommend that the District review the compliance requirements of the grant program and evaluate the currently assigned responsibilities by position to ensure that an adequate system of internal controls, including proper segregation of duties, exists.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 Child Nutrition Cluster - Segregation of Duties
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-375628-DPI-SB-546, 2023-375628-DPI-NSL-547
Award period: July 1, 2022 – June 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
• Other Matters
Compliance Requirements: Eligibility, Procurement, Reporting
Criteria or Specific Requirement: Uniform Guidance requires entities that expend federal funds are required to implement a system of internal controls to ensure that the entity remains in compliance with the requirements of the grant. 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: For activities related to Eligibility, Procurement, and Reporting, the District had not established procedures related to the documenting of the review and approval of the compliance requirements. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: During our testing we noted no review of the calculation of eligibility for the five applications submitted for testing, no review of the six monthly reports selected for testing, no approval on eight of the eleven micro-purchase transactions, and no documentation to support the price comparison for two of the three small purchase transactions selected for testing.
Cause: The District has not established policies to identify an individual to review the District’s compliance with the federal awards and how their review and approval is documented
Effect: Without an adequately designed system of internal controls over compliance, the District has an increased risk of non-compliance with the grant requirements. These risks include providing or denying benefits incorrectly, misreporting activities, or violating federal procurement requirements.
Repeat Finding: Repeat of Finding 2022-004 and 2022-005
Recommendation: We recommend that the District review the compliance requirements of the grant program and evaluate the currently assigned responsibilities by position to ensure that an adequate system of internal controls, including proper segregation of duties, exists.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 ESSER - Segregation of Duties – Grant Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief Fund
Assistance Listing Number: 84.425D, 84.425U
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2021-375628-DPI-ESSERF-160, 2022-375628-DPI-ESSERFII-163, 2023-375628-DPI-LETRS-165
Award period: March 13, 2020 – September 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
Compliance Requirements: Reporting
Criteria or Specific Requirement: Grant Reports filed by the District to the various granting agencies must be accurate and reconcile to the District’s records. Internal controls should be designed and implemented to prevent and detect errors in the data reported on the grant claims. 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: There was no review of the reports and claims for reimbursement by someone other than the preparer prior to submission. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: Of the two sampled reports, none of the reports had sign off or final reviews indicating review and approval had occurred prior to submission to the federal government.
Cause: The District currently has the business manager compile the data and prepare the reports based on data from the District’s software. However, the District has not designated an individual to review and approve the report prior to submission to ensure there was not an error during the compilation and preparation procedure.
Effect: The District may incorrectly report certain activities.
Repeat Finding: No
Recommendation: We recommend that the District implement a review process over the reporting requirements related to the ESSER grants.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 ESSER - Segregation of Duties – Grant Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief Fund
Assistance Listing Number: 84.425D, 84.425U
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2021-375628-DPI-ESSERF-160, 2022-375628-DPI-ESSERFII-163, 2023-375628-DPI-LETRS-165
Award period: March 13, 2020 – September 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
Compliance Requirements: Reporting
Criteria or Specific Requirement: Grant Reports filed by the District to the various granting agencies must be accurate and reconcile to the District’s records. Internal controls should be designed and implemented to prevent and detect errors in the data reported on the grant claims. 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: There was no review of the reports and claims for reimbursement by someone other than the preparer prior to submission. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: Of the two sampled reports, none of the reports had sign off or final reviews indicating review and approval had occurred prior to submission to the federal government.
Cause: The District currently has the business manager compile the data and prepare the reports based on data from the District’s software. However, the District has not designated an individual to review and approve the report prior to submission to ensure there was not an error during the compilation and preparation procedure.
Effect: The District may incorrectly report certain activities.
Repeat Finding: No
Recommendation: We recommend that the District implement a review process over the reporting requirements related to the ESSER grants.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 ESSER - Segregation of Duties – Grant Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief Fund
Assistance Listing Number: 84.425D, 84.425U
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2021-375628-DPI-ESSERF-160, 2022-375628-DPI-ESSERFII-163, 2023-375628-DPI-LETRS-165
Award period: March 13, 2020 – September 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
Compliance Requirements: Reporting
Criteria or Specific Requirement: Grant Reports filed by the District to the various granting agencies must be accurate and reconcile to the District’s records. Internal controls should be designed and implemented to prevent and detect errors in the data reported on the grant claims. 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: There was no review of the reports and claims for reimbursement by someone other than the preparer prior to submission. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: Of the two sampled reports, none of the reports had sign off or final reviews indicating review and approval had occurred prior to submission to the federal government.
Cause: The District currently has the business manager compile the data and prepare the reports based on data from the District’s software. However, the District has not designated an individual to review and approve the report prior to submission to ensure there was not an error during the compilation and preparation procedure.
Effect: The District may incorrectly report certain activities.
Repeat Finding: No
Recommendation: We recommend that the District implement a review process over the reporting requirements related to the ESSER grants.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 Child Nutrition Cluster - Segregation of Duties
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-375628-DPI-SB-546, 2023-375628-DPI-NSL-547
Award period: July 1, 2022 – June 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
• Other Matters
Compliance Requirements: Eligibility, Procurement, Reporting
Criteria or Specific Requirement: Uniform Guidance requires entities that expend federal funds are required to implement a system of internal controls to ensure that the entity remains in compliance with the requirements of the grant. 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: For activities related to Eligibility, Procurement, and Reporting, the District had not established procedures related to the documenting of the review and approval of the compliance requirements. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: During our testing we noted no review of the calculation of eligibility for the five applications submitted for testing, no review of the six monthly reports selected for testing, no approval on eight of the eleven micro-purchase transactions, and no documentation to support the price comparison for two of the three small purchase transactions selected for testing.
Cause: The District has not established policies to identify an individual to review the District’s compliance with the federal awards and how their review and approval is documented
Effect: Without an adequately designed system of internal controls over compliance, the District has an increased risk of non-compliance with the grant requirements. These risks include providing or denying benefits incorrectly, misreporting activities, or violating federal procurement requirements.
Repeat Finding: Repeat of Finding 2022-004 and 2022-005
Recommendation: We recommend that the District review the compliance requirements of the grant program and evaluate the currently assigned responsibilities by position to ensure that an adequate system of internal controls, including proper segregation of duties, exists.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 Child Nutrition Cluster - Segregation of Duties
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-375628-DPI-SB-546, 2023-375628-DPI-NSL-547
Award period: July 1, 2022 – June 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
• Other Matters
Compliance Requirements: Eligibility, Procurement, Reporting
Criteria or Specific Requirement: Uniform Guidance requires entities that expend federal funds are required to implement a system of internal controls to ensure that the entity remains in compliance with the requirements of the grant. 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: For activities related to Eligibility, Procurement, and Reporting, the District had not established procedures related to the documenting of the review and approval of the compliance requirements. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: During our testing we noted no review of the calculation of eligibility for the five applications submitted for testing, no review of the six monthly reports selected for testing, no approval on eight of the eleven micro-purchase transactions, and no documentation to support the price comparison for two of the three small purchase transactions selected for testing.
Cause: The District has not established policies to identify an individual to review the District’s compliance with the federal awards and how their review and approval is documented
Effect: Without an adequately designed system of internal controls over compliance, the District has an increased risk of non-compliance with the grant requirements. These risks include providing or denying benefits incorrectly, misreporting activities, or violating federal procurement requirements.
Repeat Finding: Repeat of Finding 2022-004 and 2022-005
Recommendation: We recommend that the District review the compliance requirements of the grant program and evaluate the currently assigned responsibilities by position to ensure that an adequate system of internal controls, including proper segregation of duties, exists.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003 Child Nutrition Cluster - Segregation of Duties
Federal Agency: U.S. Department of Agriculture
Federal Program Title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2023-375628-DPI-SB-546, 2023-375628-DPI-NSL-547
Award period: July 1, 2022 – June 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
• Other Matters
Compliance Requirements: Eligibility, Procurement, Reporting
Criteria or Specific Requirement: Uniform Guidance requires entities that expend federal funds are required to implement a system of internal controls to ensure that the entity remains in compliance with the requirements of the grant. 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: For activities related to Eligibility, Procurement, and Reporting, the District had not established procedures related to the documenting of the review and approval of the compliance requirements. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: During our testing we noted no review of the calculation of eligibility for the five applications submitted for testing, no review of the six monthly reports selected for testing, no approval on eight of the eleven micro-purchase transactions, and no documentation to support the price comparison for two of the three small purchase transactions selected for testing.
Cause: The District has not established policies to identify an individual to review the District’s compliance with the federal awards and how their review and approval is documented
Effect: Without an adequately designed system of internal controls over compliance, the District has an increased risk of non-compliance with the grant requirements. These risks include providing or denying benefits incorrectly, misreporting activities, or violating federal procurement requirements.
Repeat Finding: Repeat of Finding 2022-004 and 2022-005
Recommendation: We recommend that the District review the compliance requirements of the grant program and evaluate the currently assigned responsibilities by position to ensure that an adequate system of internal controls, including proper segregation of duties, exists.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 ESSER - Segregation of Duties – Grant Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief Fund
Assistance Listing Number: 84.425D, 84.425U
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2021-375628-DPI-ESSERF-160, 2022-375628-DPI-ESSERFII-163, 2023-375628-DPI-LETRS-165
Award period: March 13, 2020 – September 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
Compliance Requirements: Reporting
Criteria or Specific Requirement: Grant Reports filed by the District to the various granting agencies must be accurate and reconcile to the District’s records. Internal controls should be designed and implemented to prevent and detect errors in the data reported on the grant claims. 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: There was no review of the reports and claims for reimbursement by someone other than the preparer prior to submission. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: Of the two sampled reports, none of the reports had sign off or final reviews indicating review and approval had occurred prior to submission to the federal government.
Cause: The District currently has the business manager compile the data and prepare the reports based on data from the District’s software. However, the District has not designated an individual to review and approve the report prior to submission to ensure there was not an error during the compilation and preparation procedure.
Effect: The District may incorrectly report certain activities.
Repeat Finding: No
Recommendation: We recommend that the District implement a review process over the reporting requirements related to the ESSER grants.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 ESSER - Segregation of Duties – Grant Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief Fund
Assistance Listing Number: 84.425D, 84.425U
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2021-375628-DPI-ESSERF-160, 2022-375628-DPI-ESSERFII-163, 2023-375628-DPI-LETRS-165
Award period: March 13, 2020 – September 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
Compliance Requirements: Reporting
Criteria or Specific Requirement: Grant Reports filed by the District to the various granting agencies must be accurate and reconcile to the District’s records. Internal controls should be designed and implemented to prevent and detect errors in the data reported on the grant claims. 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: There was no review of the reports and claims for reimbursement by someone other than the preparer prior to submission. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: Of the two sampled reports, none of the reports had sign off or final reviews indicating review and approval had occurred prior to submission to the federal government.
Cause: The District currently has the business manager compile the data and prepare the reports based on data from the District’s software. However, the District has not designated an individual to review and approve the report prior to submission to ensure there was not an error during the compilation and preparation procedure.
Effect: The District may incorrectly report certain activities.
Repeat Finding: No
Recommendation: We recommend that the District implement a review process over the reporting requirements related to the ESSER grants.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 ESSER - Segregation of Duties – Grant Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Elementary and Secondary School Emergency Relief Fund
Assistance Listing Number: 84.425D, 84.425U
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Entity Identifying Number: 2021-375628-DPI-ESSERF-160, 2022-375628-DPI-ESSERFII-163, 2023-375628-DPI-LETRS-165
Award period: March 13, 2020 – September 30, 2023
Type of Finding:
• Material Weakness in Internal Control Over Compliance
Compliance Requirements: Reporting
Criteria or Specific Requirement: Grant Reports filed by the District to the various granting agencies must be accurate and reconcile to the District’s records. Internal controls should be designed and implemented to prevent and detect errors in the data reported on the grant claims. 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: There was no review of the reports and claims for reimbursement by someone other than the preparer prior to submission. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over reporting compliance requirements.
Questioned Costs: None.
Context: Of the two sampled reports, none of the reports had sign off or final reviews indicating review and approval had occurred prior to submission to the federal government.
Cause: The District currently has the business manager compile the data and prepare the reports based on data from the District’s software. However, the District has not designated an individual to review and approve the report prior to submission to ensure there was not an error during the compilation and preparation procedure.
Effect: The District may incorrectly report certain activities.
Repeat Finding: No
Recommendation: We recommend that the District implement a review process over the reporting requirements related to the ESSER grants.
Views of Responsible Officials: There is no disagreement with the audit finding.