Audit 352543

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

Finding Number Compliance Deficiencies 2024-005 Special Education Cluster: Procurement, Suspension, and Debarment Federal Agency: United States Department of Education Federal program Name: Special Education Cluster Assistance Listing Number: 84.024, 84.173 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-585264-DPI-FLOW-341, 2024-585264-DPI-PRESCH-347 Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required. 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Questioned costs: None Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. In our sample of twelve vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for one vendor. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all three vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) Finding Number Compliance Deficiencies 2024-005 Special Education Cluster: Procurement, Suspension, and Debarment (Continued) Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Additionally, the District could contract with a vendor that has been suspended or debarred from receiving Federal funds. Repeat Finding: No Recommendation: We recommend that the District review its procedures to ensure that the District’s procurement policy and suspension and debarment policy are being consistently followed. We further recommend that the District require all grant administrators to receive training on Federal procurement and suspension and debarment regulations. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

Finding Number Compliance Deficiencies 2024-005 Special Education Cluster: Procurement, Suspension, and Debarment Federal Agency: United States Department of Education Federal program Name: Special Education Cluster Assistance Listing Number: 84.024, 84.173 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-585264-DPI-FLOW-341, 2024-585264-DPI-PRESCH-347 Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required. 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Questioned costs: None Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. In our sample of twelve vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for one vendor. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all three vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) Finding Number Compliance Deficiencies 2024-005 Special Education Cluster: Procurement, Suspension, and Debarment (Continued) Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Additionally, the District could contract with a vendor that has been suspended or debarred from receiving Federal funds. Repeat Finding: No Recommendation: We recommend that the District review its procedures to ensure that the District’s procurement policy and suspension and debarment policy are being consistently followed. We further recommend that the District require all grant administrators to receive training on Federal procurement and suspension and debarment regulations. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

2024-004 Child Nutrition Cluster: Eligibility Federal Agency: United States Department of Agriculture Federal program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Number: Unknown Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Eligibility Type of Finding: Material Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Children in attendance are entitled to receive program benefits which include free or reduced lunch, if households meet stated income eligibility criteria per federal Income Eligibility Guidelines published in the Federal Register. Direct certifications are determined by the State of Wisconsin as to whether a student is to receive free, reduced or full fee lunch. This determination is entered by the District into the Food Service system. Condition: During our testing of eligibility, we noted a deviation in the eligibility determination made by the State of Wisconsin and the eligibility entered in the Food Service system. Questioned costs: None that exceed Federal threshold. Context: During our testing of eligibility, we noted that the District had entered an incorrect eligibility determination into the Food Service system for two of the forty individuals tested. The District entered in free lunch when it should have entered in reduced pricing, resulting in an incorrect count for reduced fee claims. Cause: The District experienced turnover in the Food Service Department. The District identified a resource to subsequently assume responsibilities and has received additional training and implemented appropriate procedures on a go forward basis. Effect: The District incorrectly entered two individuals for free lunch in the Food Service system when a reduced lunch should have been entered. For meals consumed by these two individuals, the counts submitted for Federal reimbursement would have been incorrect. Repeat Finding: Yes Recommendation: We recommend the District continue to enhance procedures and controls over the eligibility requirement with adequate oversight and cross-training for additional individuals knowledgeable of its requirements. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

Finding Number Compliance Deficiencies 2024-005 Special Education Cluster: Procurement, Suspension, and Debarment Federal Agency: United States Department of Education Federal program Name: Special Education Cluster Assistance Listing Number: 84.024, 84.173 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-585264-DPI-FLOW-341, 2024-585264-DPI-PRESCH-347 Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required. 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Questioned costs: None Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. In our sample of twelve vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for one vendor. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all three vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) Finding Number Compliance Deficiencies 2024-005 Special Education Cluster: Procurement, Suspension, and Debarment (Continued) Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Additionally, the District could contract with a vendor that has been suspended or debarred from receiving Federal funds. Repeat Finding: No Recommendation: We recommend that the District review its procedures to ensure that the District’s procurement policy and suspension and debarment policy are being consistently followed. We further recommend that the District require all grant administrators to receive training on Federal procurement and suspension and debarment regulations. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

Finding Number Compliance Deficiencies 2024-005 Special Education Cluster: Procurement, Suspension, and Debarment Federal Agency: United States Department of Education Federal program Name: Special Education Cluster Assistance Listing Number: 84.024, 84.173 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-585264-DPI-FLOW-341, 2024-585264-DPI-PRESCH-347 Award Period: 07/01/2023 – 06/30/2024 Compliance Requirements Affected: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2) and that the procurement is vendor aggregate, not single item. Proposals must be solicited from an adequate number of qualified offerors. For purchases greater than $250,000, either a sealed bid or proposal is required. 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Questioned costs: None Context: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. In our sample of twelve vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for one vendor. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all three vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) Finding Number Compliance Deficiencies 2024-005 Special Education Cluster: Procurement, Suspension, and Debarment (Continued) Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Additionally, the District could contract with a vendor that has been suspended or debarred from receiving Federal funds. Repeat Finding: No Recommendation: We recommend that the District review its procedures to ensure that the District’s procurement policy and suspension and debarment policy are being consistently followed. We further recommend that the District require all grant administrators to receive training on Federal procurement and suspension and debarment regulations. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.