Federal Agency: U.S. Department of Education
Federal Program Name: Title I Grant to Local Educational Agencies
Assistance Listing Number: 84.010
Federal Award Identification Number and Year: S010A220049; 2022
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2023-401253-DPI-TI-A-141
Award Period: July 1, 2022 through June 30 ,2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23),(25)) required to remove a student from the cohort, a school or Local Education Authorities (LEA) must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased.
Condition: The District did not retain document to support the removal of students from the adjusted cohort.
Questioned costs: None
Context: The District was not able to provide to the auditor documentation of the process to track and monitor the documentation of students removed from the adjust cohort. In addition, no documentation was available to review for any students removed from the adjusted cohort.
Cause: The District did not design and implement internal controls to ensure the documentation was retained for any students removed from the adjusted cohort.
Effect: The adjusted cohort may not include all student required for the calculation.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement procedures and internal controls to ensure proper documentation is obtained and retained for any students removed from the adjusted cohort.
Federal Agency: U.S. Department of Education
Federal Program Name: Title I grant to Local Educational Agencies
Assistance Listing Number: 84.010
Federal Award Identification Number and Year: S010A220049; 2022
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2023-401253-DPI-TI-A-141
Award Period: July 1, 2022 through June 30 ,2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: Title I, Section 1111(b)(2)(B)(iii) required that the Local Education Authorities (LEA) design and implement policies and procedures for ensuring that the LEA and its schools implement test security measures.
Condition: The District did not design, document or implement test security measures in compliance with Title I requirements.
Questioned costs: None
Context: The District was not able to provide to the auditor documentation of the design or implementation of test security policy that comply with the requirements of Title I.
Cause: The District did not monitor or document compliance with the requirement to design, document or implement test security.
Effect: The District may not be in compliance with requirements to ensure test security in compliance with their State Education Authority requirements and Title I requirements.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement test security measures and internal controls to ensure these policies comply with requirements of Title I.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: 2 CFR section 200.313(d)(1) requires property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Condition: The District’s capital asset records do not include all of the required aspects of property records as required by Uniform Guidance. The detail capital asset records do not identify the source of the funding for the property or the percentage of federal participation in the project costs for the federal award under which the property was acquired.
Questioned costs: None
Context: The Districts capital asset records are not currently designed to track the source and percentage of federal participation in a project as the District does not commonly utilize federal funding for capital purchases.
Cause: The District has not designed and implemented controls to ensure capital asset records included all necessary information for assets purchased with federal awards.
Effect: Capital asset records for assets purchased, wholly or partially, with federal awards do not include all necessary details as required by Uniform Guidance.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement capital asset record procedures and controls that ensure all necessary information is track in capital asset records for assets purchased with federal awards.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: 2 CFR section 200.313(d)(1) requires property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Condition: The District’s capital asset records do not include all of the required aspects of property records as required by Uniform Guidance. The detail capital asset records do not identify the source of the funding for the property or the percentage of federal participation in the project costs for the federal award under which the property was acquired.
Questioned costs: None
Context: The Districts capital asset records are not currently designed to track the source and percentage of federal participation in a project as the District does not commonly utilize federal funding for capital purchases.
Cause: The District has not designed and implemented controls to ensure capital asset records included all necessary information for assets purchased with federal awards.
Effect: Capital asset records for assets purchased, wholly or partially, with federal awards do not include all necessary details as required by Uniform Guidance.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement capital asset record procedures and controls that ensure all necessary information is track in capital asset records for assets purchased with federal awards.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: 2 CFR section 200.313(d)(1) requires property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Condition: The District’s capital asset records do not include all of the required aspects of property records as required by Uniform Guidance. The detail capital asset records do not identify the source of the funding for the property or the percentage of federal participation in the project costs for the federal award under which the property was acquired.
Questioned costs: None
Context: The Districts capital asset records are not currently designed to track the source and percentage of federal participation in a project as the District does not commonly utilize federal funding for capital purchases.
Cause: The District has not designed and implemented controls to ensure capital asset records included all necessary information for assets purchased with federal awards.
Effect: Capital asset records for assets purchased, wholly or partially, with federal awards do not include all necessary details as required by Uniform Guidance.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement capital asset record procedures and controls that ensure all necessary information is track in capital asset records for assets purchased with federal awards.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: 29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction requires that all nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations.
Condition: During testing of both of the qualifying contracts for selected for testing for compliance with requirements of the Davis-Bacon Act. Neither contract contained requirement clauses communicating required compliance with Davis-Bacon Act provisions.
Questioned costs: None
Context: The agreements entered into during the fiscal year under audit were for project that were below the scope the contractor and District require full contracts for. As such simplified agreements were entered, which did not include written Davis-Bacon Act clauses.
Cause: The District did not design and implement controls to ensure contract qualifying for Davis-Bacon Act compliance included all required clauses.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not have been conducted in compliance with such requirements.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure all necessary clauses, provisions and languages in included in contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: 29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction requires that all nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations.
Condition: During testing of both of the qualifying contracts for selected for testing for compliance with requirements of the Davis-Bacon Act. Neither contract contained requirement clauses communicating required compliance with Davis-Bacon Act provisions.
Questioned costs: None
Context: The agreements entered into during the fiscal year under audit were for project that were below the scope the contractor and District require full contracts for. As such simplified agreements were entered, which did not include written Davis-Bacon Act clauses.
Cause: The District did not design and implement controls to ensure contract qualifying for Davis-Bacon Act compliance included all required clauses.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not have been conducted in compliance with such requirements.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure all necessary clauses, provisions and languages in included in contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: 29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction requires that all nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations.
Condition: During testing of both of the qualifying contracts for selected for testing for compliance with requirements of the Davis-Bacon Act. Neither contract contained requirement clauses communicating required compliance with Davis-Bacon Act provisions.
Questioned costs: None
Context: The agreements entered into during the fiscal year under audit were for project that were below the scope the contractor and District require full contracts for. As such simplified agreements were entered, which did not include written Davis-Bacon Act clauses.
Cause: The District did not design and implement controls to ensure contract qualifying for Davis-Bacon Act compliance included all required clauses.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not have been conducted in compliance with such requirements.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure all necessary clauses, provisions and languages in included in contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls).
Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll.
Questioned costs: None
Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements.
Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay..
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls).
Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll.
Questioned costs: None
Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements.
Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay..
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls).
Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll.
Questioned costs: None
Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements.
Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay..
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls).
Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll.
Questioned costs: None
Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements.
Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay..
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Title I Grant to Local Educational Agencies
Assistance Listing Number: 84.010
Federal Award Identification Number and Year: S010A220049; 2022
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2023-401253-DPI-TI-A-141
Award Period: July 1, 2022 through June 30 ,2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23),(25)) required to remove a student from the cohort, a school or Local Education Authorities (LEA) must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased.
Condition: The District did not retain document to support the removal of students from the adjusted cohort.
Questioned costs: None
Context: The District was not able to provide to the auditor documentation of the process to track and monitor the documentation of students removed from the adjust cohort. In addition, no documentation was available to review for any students removed from the adjusted cohort.
Cause: The District did not design and implement internal controls to ensure the documentation was retained for any students removed from the adjusted cohort.
Effect: The adjusted cohort may not include all student required for the calculation.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement procedures and internal controls to ensure proper documentation is obtained and retained for any students removed from the adjusted cohort.
Federal Agency: U.S. Department of Education
Federal Program Name: Title I Grant to Local Educational Agencies
Assistance Listing Number: 84.010
Federal Award Identification Number and Year: S010A220049; 2022
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2023-401253-DPI-TI-A-141
Award Period: July 1, 2022 through June 30 ,2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23),(25)) required to remove a student from the cohort, a school or Local Education Authorities (LEA) must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased.
Condition: The District did not retain document to support the removal of students from the adjusted cohort.
Questioned costs: None
Context: The District was not able to provide to the auditor documentation of the process to track and monitor the documentation of students removed from the adjust cohort. In addition, no documentation was available to review for any students removed from the adjusted cohort.
Cause: The District did not design and implement internal controls to ensure the documentation was retained for any students removed from the adjusted cohort.
Effect: The adjusted cohort may not include all student required for the calculation.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement procedures and internal controls to ensure proper documentation is obtained and retained for any students removed from the adjusted cohort.
Federal Agency: U.S. Department of Education
Federal Program Name: Title I grant to Local Educational Agencies
Assistance Listing Number: 84.010
Federal Award Identification Number and Year: S010A220049; 2022
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2023-401253-DPI-TI-A-141
Award Period: July 1, 2022 through June 30 ,2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: Title I, Section 1111(b)(2)(B)(iii) required that the Local Education Authorities (LEA) design and implement policies and procedures for ensuring that the LEA and its schools implement test security measures.
Condition: The District did not design, document or implement test security measures in compliance with Title I requirements.
Questioned costs: None
Context: The District was not able to provide to the auditor documentation of the design or implementation of test security policy that comply with the requirements of Title I.
Cause: The District did not monitor or document compliance with the requirement to design, document or implement test security.
Effect: The District may not be in compliance with requirements to ensure test security in compliance with their State Education Authority requirements and Title I requirements.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement test security measures and internal controls to ensure these policies comply with requirements of Title I.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: 2 CFR section 200.313(d)(1) requires property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Condition: The District’s capital asset records do not include all of the required aspects of property records as required by Uniform Guidance. The detail capital asset records do not identify the source of the funding for the property or the percentage of federal participation in the project costs for the federal award under which the property was acquired.
Questioned costs: None
Context: The Districts capital asset records are not currently designed to track the source and percentage of federal participation in a project as the District does not commonly utilize federal funding for capital purchases.
Cause: The District has not designed and implemented controls to ensure capital asset records included all necessary information for assets purchased with federal awards.
Effect: Capital asset records for assets purchased, wholly or partially, with federal awards do not include all necessary details as required by Uniform Guidance.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement capital asset record procedures and controls that ensure all necessary information is track in capital asset records for assets purchased with federal awards.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: 2 CFR section 200.313(d)(1) requires property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Condition: The District’s capital asset records do not include all of the required aspects of property records as required by Uniform Guidance. The detail capital asset records do not identify the source of the funding for the property or the percentage of federal participation in the project costs for the federal award under which the property was acquired.
Questioned costs: None
Context: The Districts capital asset records are not currently designed to track the source and percentage of federal participation in a project as the District does not commonly utilize federal funding for capital purchases.
Cause: The District has not designed and implemented controls to ensure capital asset records included all necessary information for assets purchased with federal awards.
Effect: Capital asset records for assets purchased, wholly or partially, with federal awards do not include all necessary details as required by Uniform Guidance.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement capital asset record procedures and controls that ensure all necessary information is track in capital asset records for assets purchased with federal awards.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: 2 CFR section 200.313(d)(1) requires property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Condition: The District’s capital asset records do not include all of the required aspects of property records as required by Uniform Guidance. The detail capital asset records do not identify the source of the funding for the property or the percentage of federal participation in the project costs for the federal award under which the property was acquired.
Questioned costs: None
Context: The Districts capital asset records are not currently designed to track the source and percentage of federal participation in a project as the District does not commonly utilize federal funding for capital purchases.
Cause: The District has not designed and implemented controls to ensure capital asset records included all necessary information for assets purchased with federal awards.
Effect: Capital asset records for assets purchased, wholly or partially, with federal awards do not include all necessary details as required by Uniform Guidance.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement capital asset record procedures and controls that ensure all necessary information is track in capital asset records for assets purchased with federal awards.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: 29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction requires that all nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations.
Condition: During testing of both of the qualifying contracts for selected for testing for compliance with requirements of the Davis-Bacon Act. Neither contract contained requirement clauses communicating required compliance with Davis-Bacon Act provisions.
Questioned costs: None
Context: The agreements entered into during the fiscal year under audit were for project that were below the scope the contractor and District require full contracts for. As such simplified agreements were entered, which did not include written Davis-Bacon Act clauses.
Cause: The District did not design and implement controls to ensure contract qualifying for Davis-Bacon Act compliance included all required clauses.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not have been conducted in compliance with such requirements.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure all necessary clauses, provisions and languages in included in contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: 29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction requires that all nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations.
Condition: During testing of both of the qualifying contracts for selected for testing for compliance with requirements of the Davis-Bacon Act. Neither contract contained requirement clauses communicating required compliance with Davis-Bacon Act provisions.
Questioned costs: None
Context: The agreements entered into during the fiscal year under audit were for project that were below the scope the contractor and District require full contracts for. As such simplified agreements were entered, which did not include written Davis-Bacon Act clauses.
Cause: The District did not design and implement controls to ensure contract qualifying for Davis-Bacon Act compliance included all required clauses.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not have been conducted in compliance with such requirements.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure all necessary clauses, provisions and languages in included in contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: 29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction requires that all nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations.
Condition: During testing of both of the qualifying contracts for selected for testing for compliance with requirements of the Davis-Bacon Act. Neither contract contained requirement clauses communicating required compliance with Davis-Bacon Act provisions.
Questioned costs: None
Context: The agreements entered into during the fiscal year under audit were for project that were below the scope the contractor and District require full contracts for. As such simplified agreements were entered, which did not include written Davis-Bacon Act clauses.
Cause: The District did not design and implement controls to ensure contract qualifying for Davis-Bacon Act compliance included all required clauses.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not have been conducted in compliance with such requirements.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure all necessary clauses, provisions and languages in included in contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls).
Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll.
Questioned costs: None
Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements.
Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay..
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls).
Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll.
Questioned costs: None
Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements.
Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay..
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls).
Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll.
Questioned costs: None
Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements.
Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay..
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund
Assistance Listing Number: 84.425D & 84.425C
Federal Award Identification Number and Year: 2021
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165
Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls).
Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll.
Questioned costs: None
Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements.
Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions.
Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay..
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Name: Title I Grant to Local Educational Agencies
Assistance Listing Number: 84.010
Federal Award Identification Number and Year: S010A220049; 2022
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2023-401253-DPI-TI-A-141
Award Period: July 1, 2022 through June 30 ,2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion)
Criteria or specific requirement: ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23),(25)) required to remove a student from the cohort, a school or Local Education Authorities (LEA) must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased.
Condition: The District did not retain document to support the removal of students from the adjusted cohort.
Questioned costs: None
Context: The District was not able to provide to the auditor documentation of the process to track and monitor the documentation of students removed from the adjust cohort. In addition, no documentation was available to review for any students removed from the adjusted cohort.
Cause: The District did not design and implement internal controls to ensure the documentation was retained for any students removed from the adjusted cohort.
Effect: The adjusted cohort may not include all student required for the calculation.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend the District design and implement procedures and internal controls to ensure proper documentation is obtained and retained for any students removed from the adjusted cohort.