Finding 2024-003: Significant Deficiency - Internal Control and Compliance Over Procurement
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: Guidance provided in 2 CFR part 200.318 requires non-federal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. A system of internal controls should be in place to ensure procurement policies are being adhered to. There are also requirements to verify the vendors are not suspended or debarred.
Condition/Context: There was no documented approval of one of the two procurements tested. The food service director handled the procurement of kitchen equipment and no documentation of review by a different appropriate individual was noted. Additionally, it is unclear whether suspension or debarment of the vendor was considered. The sample was not a statistically valid sample.
Cause: District policy for procurement was not enforced.
Effect: This could potentially lead to higher costs for the food service program or selection of vendors who are not eligible to be paid with federal funds.
Questioned Costs: None noted.
Recommendation: Program personnel should become familiar with the procurement, suspension and debarment rules for federal programs and the District's policies and implement process changes as soon as possible.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-003: Significant Deficiency - Internal Control and Compliance Over Procurement
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: Guidance provided in 2 CFR part 200.318 requires non-federal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. A system of internal controls should be in place to ensure procurement policies are being adhered to. There are also requirements to verify the vendors are not suspended or debarred.
Condition/Context: There was no documented approval of one of the two procurements tested. The food service director handled the procurement of kitchen equipment and no documentation of review by a different appropriate individual was noted. Additionally, it is unclear whether suspension or debarment of the vendor was considered. The sample was not a statistically valid sample.
Cause: District policy for procurement was not enforced.
Effect: This could potentially lead to higher costs for the food service program or selection of vendors who are not eligible to be paid with federal funds.
Questioned Costs: None noted.
Recommendation: Program personnel should become familiar with the procurement, suspension and debarment rules for federal programs and the District's policies and implement process changes as soon as possible.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-003: Significant Deficiency - Internal Control and Compliance Over Procurement
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: Guidance provided in 2 CFR part 200.318 requires non-federal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. A system of internal controls should be in place to ensure procurement policies are being adhered to. There are also requirements to verify the vendors are not suspended or debarred.
Condition/Context: There was no documented approval of one of the two procurements tested. The food service director handled the procurement of kitchen equipment and no documentation of review by a different appropriate individual was noted. Additionally, it is unclear whether suspension or debarment of the vendor was considered. The sample was not a statistically valid sample.
Cause: District policy for procurement was not enforced.
Effect: This could potentially lead to higher costs for the food service program or selection of vendors who are not eligible to be paid with federal funds.
Questioned Costs: None noted.
Recommendation: Program personnel should become familiar with the procurement, suspension and debarment rules for federal programs and the District's policies and implement process changes as soon as possible.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-004: Significant Deficiency - Internal Control over Reporting
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: A system of internal control should be in place and operating effectively to achieve a higher reliability that errors or irregularities in reporting would be discovered by District staff.
Condition/Context: The four claims selected for testing had supporting documentation prepared by the same person who prepared and submitted the claims. Food service claims and supporting documentation are prepared by the same person, and there is a lack of documented review by someone other than the original preparer. The sample was not a statistically valid sample.
Cause: There is a lack of documentation of review by someone other than the original preparer of food service claims.
Effect: Without proper review of claims, incorrect amounts could be claimed on the reports and could result in over (or under) funding.
Questioned Costs: None noted.
Recommendation: The District should implement a system in which one person prepares the report and another reviews to ensure it is correct prior to submission. Documentation of review should be maintained.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-004: Significant Deficiency - Internal Control over Reporting
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: A system of internal control should be in place and operating effectively to achieve a higher reliability that errors or irregularities in reporting would be discovered by District staff.
Condition/Context: The four claims selected for testing had supporting documentation prepared by the same person who prepared and submitted the claims. Food service claims and supporting documentation are prepared by the same person, and there is a lack of documented review by someone other than the original preparer. The sample was not a statistically valid sample.
Cause: There is a lack of documentation of review by someone other than the original preparer of food service claims.
Effect: Without proper review of claims, incorrect amounts could be claimed on the reports and could result in over (or under) funding.
Questioned Costs: None noted.
Recommendation: The District should implement a system in which one person prepares the report and another reviews to ensure it is correct prior to submission. Documentation of review should be maintained.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-004: Significant Deficiency - Internal Control over Reporting
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: A system of internal control should be in place and operating effectively to achieve a higher reliability that errors or irregularities in reporting would be discovered by District staff.
Condition/Context: The four claims selected for testing had supporting documentation prepared by the same person who prepared and submitted the claims. Food service claims and supporting documentation are prepared by the same person, and there is a lack of documented review by someone other than the original preparer. The sample was not a statistically valid sample.
Cause: There is a lack of documentation of review by someone other than the original preparer of food service claims.
Effect: Without proper review of claims, incorrect amounts could be claimed on the reports and could result in over (or under) funding.
Questioned Costs: None noted.
Recommendation: The District should implement a system in which one person prepares the report and another reviews to ensure it is correct prior to submission. Documentation of review should be maintained.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Program: Medicaid Cluster
Assistance Listing Number: 93.778
Pass-Through Agency: Wisconsin Department of Health
Criteria: A system of internal control should be in place and operating effectively to achieve a higher reliability that errors or irregularities in reporting would be discovered by District staff.
Condition/Context: Two Quarterly Financial Summaries and Annual Cost reports tested were prepared without documentation of review by someone other than the original preparer. The reports had clerical errors but did not result in over reporting expenditures of the program. The sample was not a statistically valid sample.
Cause: There is no review by someone other than the original preparer of Quarterly Financial Summaries and Annual Cost reports.
Effect: Without proper review of claims, incorrect amounts could be claimed on the reports and could result in over (or under) funding.
Questioned Costs: None noted.
Recommendation: A system should be put in place for the District to sufficiently document the review of Quarterly Financial Summaries and the Annual Cost report.
Views of Responsible Officials: Management agrees with finding 2024-004 and will make efforts to implement recommended procedures. Management submitted corrected versions of the tested Quarterly Financial Summaries to SBS after audit fieldwork.
Finding 2024-006: Significant Deficiency - Internal Control and Compliance Over Special Tests
and Provisions
Program: Medicaid Cluster
Assistance Listing Number: 93.778
Pass-Through Agency: Wisconsin Department of Health
Criteria: The District should have a process in place to identify total one-way student trips for reporting in the annual report. This process should include reviews by someone independent of the reporting to ensure data is accurate and properly reported in the annual report.
Condition/Context: Incorrect or incomplete information was compiled into the spreadsheet used to calculate the one-way trips for the annual report. Both months tested had a student whose bus logs were not entered accurately into the spreadsheet used to calculate one-way trips for the annual report, each instance being a different student. In addition, in one of the months, a different student's bus log was incorrectly counted in the spreadsheet. The sample was not a statistically valid sample.
Cause: Inadequate review was performed over the information provided for the annual report, and no review was performed to ensure the annual report aligned with the supporting documentation.
Effect: Inaccurate reporting may cause the District to receive more or less funding than they are entitled to.
Questioned Costs: None noted.
Recommendation: The District should have a process in place to review data provided for one-way trips reported in the annual report, which should include ensuring data is accurate and that correct information was entered into the annual report.
Views of Responsible Officials: Management agrees with finding 2024-005 and will make efforts to implement recommended procedures.
Finding 2024-003: Significant Deficiency - Internal Control and Compliance Over Procurement
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: Guidance provided in 2 CFR part 200.318 requires non-federal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. A system of internal controls should be in place to ensure procurement policies are being adhered to. There are also requirements to verify the vendors are not suspended or debarred.
Condition/Context: There was no documented approval of one of the two procurements tested. The food service director handled the procurement of kitchen equipment and no documentation of review by a different appropriate individual was noted. Additionally, it is unclear whether suspension or debarment of the vendor was considered. The sample was not a statistically valid sample.
Cause: District policy for procurement was not enforced.
Effect: This could potentially lead to higher costs for the food service program or selection of vendors who are not eligible to be paid with federal funds.
Questioned Costs: None noted.
Recommendation: Program personnel should become familiar with the procurement, suspension and debarment rules for federal programs and the District's policies and implement process changes as soon as possible.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-003: Significant Deficiency - Internal Control and Compliance Over Procurement
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: Guidance provided in 2 CFR part 200.318 requires non-federal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. A system of internal controls should be in place to ensure procurement policies are being adhered to. There are also requirements to verify the vendors are not suspended or debarred.
Condition/Context: There was no documented approval of one of the two procurements tested. The food service director handled the procurement of kitchen equipment and no documentation of review by a different appropriate individual was noted. Additionally, it is unclear whether suspension or debarment of the vendor was considered. The sample was not a statistically valid sample.
Cause: District policy for procurement was not enforced.
Effect: This could potentially lead to higher costs for the food service program or selection of vendors who are not eligible to be paid with federal funds.
Questioned Costs: None noted.
Recommendation: Program personnel should become familiar with the procurement, suspension and debarment rules for federal programs and the District's policies and implement process changes as soon as possible.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-003: Significant Deficiency - Internal Control and Compliance Over Procurement
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: Guidance provided in 2 CFR part 200.318 requires non-federal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. A system of internal controls should be in place to ensure procurement policies are being adhered to. There are also requirements to verify the vendors are not suspended or debarred.
Condition/Context: There was no documented approval of one of the two procurements tested. The food service director handled the procurement of kitchen equipment and no documentation of review by a different appropriate individual was noted. Additionally, it is unclear whether suspension or debarment of the vendor was considered. The sample was not a statistically valid sample.
Cause: District policy for procurement was not enforced.
Effect: This could potentially lead to higher costs for the food service program or selection of vendors who are not eligible to be paid with federal funds.
Questioned Costs: None noted.
Recommendation: Program personnel should become familiar with the procurement, suspension and debarment rules for federal programs and the District's policies and implement process changes as soon as possible.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-004: Significant Deficiency - Internal Control over Reporting
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: A system of internal control should be in place and operating effectively to achieve a higher reliability that errors or irregularities in reporting would be discovered by District staff.
Condition/Context: The four claims selected for testing had supporting documentation prepared by the same person who prepared and submitted the claims. Food service claims and supporting documentation are prepared by the same person, and there is a lack of documented review by someone other than the original preparer. The sample was not a statistically valid sample.
Cause: There is a lack of documentation of review by someone other than the original preparer of food service claims.
Effect: Without proper review of claims, incorrect amounts could be claimed on the reports and could result in over (or under) funding.
Questioned Costs: None noted.
Recommendation: The District should implement a system in which one person prepares the report and another reviews to ensure it is correct prior to submission. Documentation of review should be maintained.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-004: Significant Deficiency - Internal Control over Reporting
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: A system of internal control should be in place and operating effectively to achieve a higher reliability that errors or irregularities in reporting would be discovered by District staff.
Condition/Context: The four claims selected for testing had supporting documentation prepared by the same person who prepared and submitted the claims. Food service claims and supporting documentation are prepared by the same person, and there is a lack of documented review by someone other than the original preparer. The sample was not a statistically valid sample.
Cause: There is a lack of documentation of review by someone other than the original preparer of food service claims.
Effect: Without proper review of claims, incorrect amounts could be claimed on the reports and could result in over (or under) funding.
Questioned Costs: None noted.
Recommendation: The District should implement a system in which one person prepares the report and another reviews to ensure it is correct prior to submission. Documentation of review should be maintained.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-004: Significant Deficiency - Internal Control over Reporting
Program: Child Nutrition Cluster
Assistance Listing Number: 10.553/10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Criteria: A system of internal control should be in place and operating effectively to achieve a higher reliability that errors or irregularities in reporting would be discovered by District staff.
Condition/Context: The four claims selected for testing had supporting documentation prepared by the same person who prepared and submitted the claims. Food service claims and supporting documentation are prepared by the same person, and there is a lack of documented review by someone other than the original preparer. The sample was not a statistically valid sample.
Cause: There is a lack of documentation of review by someone other than the original preparer of food service claims.
Effect: Without proper review of claims, incorrect amounts could be claimed on the reports and could result in over (or under) funding.
Questioned Costs: None noted.
Recommendation: The District should implement a system in which one person prepares the report and another reviews to ensure it is correct prior to submission. Documentation of review should be maintained.
Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Program: Medicaid Cluster
Assistance Listing Number: 93.778
Pass-Through Agency: Wisconsin Department of Health
Criteria: A system of internal control should be in place and operating effectively to achieve a higher reliability that errors or irregularities in reporting would be discovered by District staff.
Condition/Context: Two Quarterly Financial Summaries and Annual Cost reports tested were prepared without documentation of review by someone other than the original preparer. The reports had clerical errors but did not result in over reporting expenditures of the program. The sample was not a statistically valid sample.
Cause: There is no review by someone other than the original preparer of Quarterly Financial Summaries and Annual Cost reports.
Effect: Without proper review of claims, incorrect amounts could be claimed on the reports and could result in over (or under) funding.
Questioned Costs: None noted.
Recommendation: A system should be put in place for the District to sufficiently document the review of Quarterly Financial Summaries and the Annual Cost report.
Views of Responsible Officials: Management agrees with finding 2024-004 and will make efforts to implement recommended procedures. Management submitted corrected versions of the tested Quarterly Financial Summaries to SBS after audit fieldwork.
Finding 2024-006: Significant Deficiency - Internal Control and Compliance Over Special Tests
and Provisions
Program: Medicaid Cluster
Assistance Listing Number: 93.778
Pass-Through Agency: Wisconsin Department of Health
Criteria: The District should have a process in place to identify total one-way student trips for reporting in the annual report. This process should include reviews by someone independent of the reporting to ensure data is accurate and properly reported in the annual report.
Condition/Context: Incorrect or incomplete information was compiled into the spreadsheet used to calculate the one-way trips for the annual report. Both months tested had a student whose bus logs were not entered accurately into the spreadsheet used to calculate one-way trips for the annual report, each instance being a different student. In addition, in one of the months, a different student's bus log was incorrectly counted in the spreadsheet. The sample was not a statistically valid sample.
Cause: Inadequate review was performed over the information provided for the annual report, and no review was performed to ensure the annual report aligned with the supporting documentation.
Effect: Inaccurate reporting may cause the District to receive more or less funding than they are entitled to.
Questioned Costs: None noted.
Recommendation: The District should have a process in place to review data provided for one-way trips reported in the annual report, which should include ensuring data is accurate and that correct information was entered into the annual report.
Views of Responsible Officials: Management agrees with finding 2024-005 and will make efforts to implement recommended procedures.