Audit 361616

Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 State Agency: Wisconsin Department Workforce Development State Number(s): Not applicable Award Period: December 14, 2021 – June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance and Noncompliance Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred. The Organization should be updated to reflect all procurement policy requirements outlined by Uniform Guidance. Additionally, the Organization should implement policies to ensure it is not entering into a covered transaction with an entity that has been suspended or debarred, as defined in 2 CFR section 180.995. Condition: Procurement and suspension and debarment policies are not in compliance with Uniform Guidance. Therefore, the Organization did not have procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. However, per review of SAM.gov during audit testing, it was determined that no tested vendors were suspended nor debarred. Questioned costs: None Context: CLA completed procurement and suspension and debarment testing and it was noted that the Organization's related policies were not in accordance with Uniform Guidance. Additionally, CLA tested suspension and debarment procedures over the sole covered transaction to determine whether the Organization complied with the requirements for charging costs to grants passed through the Wisconsin Department of Workforce Development. There was no documentation to show that a suspension and debarment check was performed prior to entering into the covered transaction, however the Organization did perform a check via SAM.gov at a subsequent date and determined the contractor was not suspended nor debarred. Cause: The Organization was not aware of policy and documentation requirements under Uniform Guidance for procurement and suspension and debarment. Effect: Noncompliant policies can lead to selecting vendors that are suspended and debarred and could result in the procurement of goods and services that are unideal for programs. When not approved by the granting agency, not following suspension and debarment procedures is considered a form of noncompliance with the grant provision. Repeat Finding: No Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA also recommends emphasizing the importance of following those standards and established policies with all authorized purchasers within the Organization, including verifying that suspension and debarment checks are performed and documented prior to entering into covered transactions. Views of responsible officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 State Agency: Wisconsin Department Workforce Development State Number(s): Not applicable Award Period: December 14, 2021 – June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance and Noncompliance Criteria or specific requirement: The Wisconsin Department of Workforce Development requires the Organization to submit Form DETW-19457-E quarterly. Condition: The Organization did not have review procedures in place to ensure the quarterly Forms DETW-19457-E were accurately prepared and submitted timely. Questioned costs: None Context: In the statistically valid sample that CLA selected, one of two quarterly Form DETW-19457-Es was not submitted timely. Both reports tested lacked sufficient internal review prior to submission to the awarding agency. Cause: The Organization did not have sufficient internal controls over performance reporting to ensure quarterly Forms DETW-19457-E are reviewed prior to submission nor to ensure the reports are submitted timely. Effect: Lack of sufficient controls over review and submission of reports may lead to inaccurate, incomplete, and untimely reporting. Repeat Finding: No Recommendation: CLA recommends that the Organization implement procedures for verifying that Forms DETW-19457-E are reviewed and submitted timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 State Agency: Wisconsin Department Workforce Development State Number(s): Not applicable Award Period: December 14, 2021 – June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance and Noncompliance Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred. The Organization should be updated to reflect all procurement policy requirements outlined by Uniform Guidance. Additionally, the Organization should implement policies to ensure it is not entering into a covered transaction with an entity that has been suspended or debarred, as defined in 2 CFR section 180.995. Condition: Procurement and suspension and debarment policies are not in compliance with Uniform Guidance. Therefore, the Organization did not have procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. However, per review of SAM.gov during audit testing, it was determined that no tested vendors were suspended nor debarred. Questioned costs: None Context: CLA completed procurement and suspension and debarment testing and it was noted that the Organization's related policies were not in accordance with Uniform Guidance. Additionally, CLA tested suspension and debarment procedures over the sole covered transaction to determine whether the Organization complied with the requirements for charging costs to grants passed through the Wisconsin Department of Workforce Development. There was no documentation to show that a suspension and debarment check was performed prior to entering into the covered transaction, however the Organization did perform a check via SAM.gov at a subsequent date and determined the contractor was not suspended nor debarred. Cause: The Organization was not aware of policy and documentation requirements under Uniform Guidance for procurement and suspension and debarment. Effect: Noncompliant policies can lead to selecting vendors that are suspended and debarred and could result in the procurement of goods and services that are unideal for programs. When not approved by the granting agency, not following suspension and debarment procedures is considered a form of noncompliance with the grant provision. Repeat Finding: No Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA also recommends emphasizing the importance of following those standards and established policies with all authorized purchasers within the Organization, including verifying that suspension and debarment checks are performed and documented prior to entering into covered transactions. Views of responsible officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 State Agency: Wisconsin Department Workforce Development State Number(s): Not applicable Award Period: December 14, 2021 – June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance and Noncompliance Criteria or specific requirement: The Wisconsin Department of Workforce Development requires the Organization to submit Form DETW-19457-E quarterly. Condition: The Organization did not have review procedures in place to ensure the quarterly Forms DETW-19457-E were accurately prepared and submitted timely. Questioned costs: None Context: In the statistically valid sample that CLA selected, one of two quarterly Form DETW-19457-Es was not submitted timely. Both reports tested lacked sufficient internal review prior to submission to the awarding agency. Cause: The Organization did not have sufficient internal controls over performance reporting to ensure quarterly Forms DETW-19457-E are reviewed prior to submission nor to ensure the reports are submitted timely. Effect: Lack of sufficient controls over review and submission of reports may lead to inaccurate, incomplete, and untimely reporting. Repeat Finding: No Recommendation: CLA recommends that the Organization implement procedures for verifying that Forms DETW-19457-E are reviewed and submitted timely. Views of responsible officials: There is no disagreement with the audit finding.