FAC Explorer

Audit 302204

FY End
2023-06-30
Total Expended
$1.82M
Findings
12
Programs
11
Organization: Port Washington Saukville School District (WI)
Year: 2023 Accepted: 2024-04-02
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
392071 2023-002 Significant Deficiency Yes I
392072 2023-003 Significant Deficiency Yes I
392073 2023-002 Significant Deficiency Yes I
392074 2023-003 Significant Deficiency Yes I
392075 2023-002 Significant Deficiency Yes I
392076 2023-003 Significant Deficiency Yes I
968513 2023-002 Significant Deficiency Yes I
968514 2023-003 Significant Deficiency Yes I
968515 2023-002 Significant Deficiency Yes I
968516 2023-003 Significant Deficiency Yes I
968517 2023-002 Significant Deficiency Yes I
968518 2023-003 Significant Deficiency Yes I

Programs

ALN Program Spent Major Findings
84.027 Special Education_grants to States $501,116 - 0
10.555 National School Lunch Program $447,401 Yes 2
93.778 Medical Assistance Program $333,089 - 0
84.010 Title I Grants to Local Educational Agencies $180,282 - 0
84.425 Education Stabilization Fund $174,928 Yes 0
10.553 School Breakfast Program $29,536 Yes 2
84.367 Improving Teacher Quality State Grants $24,915 - 0
84.173 Special Education_preschool Grants $18,718 - 0
84.048 Career and Technical Education -- Basic Grants to States $12,323 - 0
84.424 Student Support and Academic Enrichment Program $8,222 - 0
84.365 English Language Acquisition State Grants $5,621 - 0

Contacts

Name Title Type
LYMGB4G8TXL1 Brenda Arnett Auditee
2622686081 Shannon D. Small 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 2023 fund financial statements. 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 District has not elected to charge a de minimis rate of 10% of modified total costs. The accompanying schedules of expenditures of federal and state awards for the Port Washington-Saukville School District is presented in 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, changes in net position, or cash flows of the District.
Title: Special Education and School Aged 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 2023 fund financial statements. 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 District has not elected to charge a de minimis rate of 10% of modified total costs. The 2022-2023 eligible costs under the State Special Education Program as reported by the District are $5,263,339. 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 2023 fund financial statements. 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 District has not elected to charge a de minimis rate of 10% of modified total costs. 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 2023 fund financial statements. 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 District has not elected to charge a de minimis rate of 10% of modified total costs. 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 2023 fund financial statements. 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 District has not elected to charge a de minimis rate of 10% of modified total costs. Federal and state awards have been passed through the following entities: WI DHS – Wisconsin Department of Health Services WI DPI – Wisconsin Department of Public Instruction CESA #1 – Cooperative Educational Service Agency #1

Finding Details

Finding 2023-002
2023 – 002 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policies in effect for the year under audit, it was noted that the policy in force for part of the year did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. The policy was update during the year to comply with such requirements. Questioned costs: None. Context: The District's purchasing policy updated during the year to comply the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. Prior to this update, the District's purchasing policy was had not been updated for several years and did not include all necessary aspects to comply with Uniform Guidance. Cause: The District did not complete its review and updating of the procurement prior to the beginning of year and the initiation of current contracts. Effect: The District's purchasing policy in effect during part of the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procurement methods, micro-purchase and small purchase transactions. Repeat finding: This is a repeat of finding 2022-002. Recommendation: We recommend the District should review and update, as necessary, policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-003
2023 – 003 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to non-procurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that three vendors were not suspended or debarred prior to the purchase. Questioned costs: None. Context: For the 2 vendors with purchases exceeding the threshold, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their verification and documentation of the vendor’s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation over these compliance requirements provides an opportunity for noncompliance. Repeat finding: This is a repeat of finding 2022-003. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-002
2023 – 002 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policies in effect for the year under audit, it was noted that the policy in force for part of the year did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. The policy was update during the year to comply with such requirements. Questioned costs: None. Context: The District's purchasing policy updated during the year to comply the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. Prior to this update, the District's purchasing policy was had not been updated for several years and did not include all necessary aspects to comply with Uniform Guidance. Cause: The District did not complete its review and updating of the procurement prior to the beginning of year and the initiation of current contracts. Effect: The District's purchasing policy in effect during part of the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procurement methods, micro-purchase and small purchase transactions. Repeat finding: This is a repeat of finding 2022-002. Recommendation: We recommend the District should review and update, as necessary, policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-003
2023 – 003 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to non-procurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that three vendors were not suspended or debarred prior to the purchase. Questioned costs: None. Context: For the 2 vendors with purchases exceeding the threshold, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their verification and documentation of the vendor’s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation over these compliance requirements provides an opportunity for noncompliance. Repeat finding: This is a repeat of finding 2022-003. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-002
2023 – 002 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policies in effect for the year under audit, it was noted that the policy in force for part of the year did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. The policy was update during the year to comply with such requirements. Questioned costs: None. Context: The District's purchasing policy updated during the year to comply the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. Prior to this update, the District's purchasing policy was had not been updated for several years and did not include all necessary aspects to comply with Uniform Guidance. Cause: The District did not complete its review and updating of the procurement prior to the beginning of year and the initiation of current contracts. Effect: The District's purchasing policy in effect during part of the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procurement methods, micro-purchase and small purchase transactions. Repeat finding: This is a repeat of finding 2022-002. Recommendation: We recommend the District should review and update, as necessary, policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-003
2023 – 003 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to non-procurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that three vendors were not suspended or debarred prior to the purchase. Questioned costs: None. Context: For the 2 vendors with purchases exceeding the threshold, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their verification and documentation of the vendor’s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation over these compliance requirements provides an opportunity for noncompliance. Repeat finding: This is a repeat of finding 2022-003. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-002
2023 – 002 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policies in effect for the year under audit, it was noted that the policy in force for part of the year did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. The policy was update during the year to comply with such requirements. Questioned costs: None. Context: The District's purchasing policy updated during the year to comply the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. Prior to this update, the District's purchasing policy was had not been updated for several years and did not include all necessary aspects to comply with Uniform Guidance. Cause: The District did not complete its review and updating of the procurement prior to the beginning of year and the initiation of current contracts. Effect: The District's purchasing policy in effect during part of the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procurement methods, micro-purchase and small purchase transactions. Repeat finding: This is a repeat of finding 2022-002. Recommendation: We recommend the District should review and update, as necessary, policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-003
2023 – 003 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to non-procurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that three vendors were not suspended or debarred prior to the purchase. Questioned costs: None. Context: For the 2 vendors with purchases exceeding the threshold, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their verification and documentation of the vendor’s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation over these compliance requirements provides an opportunity for noncompliance. Repeat finding: This is a repeat of finding 2022-003. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-002
2023 – 002 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policies in effect for the year under audit, it was noted that the policy in force for part of the year did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. The policy was update during the year to comply with such requirements. Questioned costs: None. Context: The District's purchasing policy updated during the year to comply the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. Prior to this update, the District's purchasing policy was had not been updated for several years and did not include all necessary aspects to comply with Uniform Guidance. Cause: The District did not complete its review and updating of the procurement prior to the beginning of year and the initiation of current contracts. Effect: The District's purchasing policy in effect during part of the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procurement methods, micro-purchase and small purchase transactions. Repeat finding: This is a repeat of finding 2022-002. Recommendation: We recommend the District should review and update, as necessary, policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-003
2023 – 003 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to non-procurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that three vendors were not suspended or debarred prior to the purchase. Questioned costs: None. Context: For the 2 vendors with purchases exceeding the threshold, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their verification and documentation of the vendor’s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation over these compliance requirements provides an opportunity for noncompliance. Repeat finding: This is a repeat of finding 2022-003. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-002
2023 – 002 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policies in effect for the year under audit, it was noted that the policy in force for part of the year did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. The policy was update during the year to comply with such requirements. Questioned costs: None. Context: The District's purchasing policy updated during the year to comply the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. Prior to this update, the District's purchasing policy was had not been updated for several years and did not include all necessary aspects to comply with Uniform Guidance. Cause: The District did not complete its review and updating of the procurement prior to the beginning of year and the initiation of current contracts. Effect: The District's purchasing policy in effect during part of the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procurement methods, micro-purchase and small purchase transactions. Repeat finding: This is a repeat of finding 2022-002. Recommendation: We recommend the District should review and update, as necessary, policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-003
2023 – 003 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to non-procurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that three vendors were not suspended or debarred prior to the purchase. Questioned costs: None. Context: For the 2 vendors with purchases exceeding the threshold, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their verification and documentation of the vendor’s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation over these compliance requirements provides an opportunity for noncompliance. Repeat finding: This is a repeat of finding 2022-003. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.