FAC Explorer

Audit 330620

FY End
2024-06-30
Total Expended
$16.97M
Findings
22
Programs
19
Organization: Sheboygan Area School District (WI)
Year: 2024 Accepted: 2024-12-03
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
512854 2024-003 Significant Deficiency Yes I
512855 2024-003 Significant Deficiency Yes I
512856 2024-003 Significant Deficiency Yes I
512857 2024-003 Significant Deficiency Yes I
512858 2024-003 Significant Deficiency Yes I
512859 2024-003 Significant Deficiency Yes I
512860 2024-003 Significant Deficiency Yes I
512861 2024-003 Significant Deficiency Yes I
512862 2024-003 Significant Deficiency Yes I
512863 2024-003 Significant Deficiency Yes I
512864 2024-003 Significant Deficiency Yes I
1089296 2024-003 Significant Deficiency Yes I
1089297 2024-003 Significant Deficiency Yes I
1089298 2024-003 Significant Deficiency Yes I
1089299 2024-003 Significant Deficiency Yes I
1089300 2024-003 Significant Deficiency Yes I
1089301 2024-003 Significant Deficiency Yes I
1089302 2024-003 Significant Deficiency Yes I
1089303 2024-003 Significant Deficiency Yes I
1089304 2024-003 Significant Deficiency Yes I
1089305 2024-003 Significant Deficiency Yes I
1089306 2024-003 Significant Deficiency Yes I

Programs

ALN Program Spent Major Findings
84.425D Education Stabilization Fund $3.87M - 0
93.778 Medical Assistance Program $1.42M - 0
10.553 School Breakfast Program $1.12M Yes 1
10.555 National School Lunch Program $459,709 Yes 1
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $409,846 - 0
84.287 Twenty-First Century Community Learning Centers $281,880 - 0
10.558 Child and Adult Care Food Program $262,474 - 0
84.365 English Language Acquisition State Grants $212,146 - 0
84.424 Student Support and Academic Enrichment Program $146,687 - 0
10.559 Summer Food Service Program for Children $93,717 Yes 1
84.048 Career and Technical Education -- Basic Grants to States $92,279 - 0
84.173 Special Education Preschool Grants $57,772 Yes 1
84.010 Title I Grants to Local Educational Agencies $52,813 Yes 0
84.196 Education for Homeless Children and Youth $36,906 - 0
10.185 Local Food for Schools Cooperative Agreement Program $36,728 - 0
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $20,649 - 0
84.027 Special Education Grants to States $16,527 Yes 1
84.425U Education Stabilization Fund $7,000 - 0
84.427W Congressionally Directed Spending�rehabilitation Services and Disability Research $4,607 - 0

Contacts

Name Title Type
V6W8BRQX6DZ9 Wendy Baackes Auditee
9204593525 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 2024 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 Sheboygan Area School District are 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 or changes in net position of the District.
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 2024 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 2024 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 2024 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 awards have been pass through the following entities: WI DHS – Wisconsin Department of Health Services WI DPI – Wisconsin Department of Public Instruction

Finding Details

Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.
Finding 2024-003
2024-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2023 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.