Audit 381858

2025-004 Segregation of Duties – Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556 Pass-Through Agency: Wisconsin Department of Instruction Pass Through Numbers: 2025-445138-DPI-SB-546, 2025-445138-DPI-NSL-547, 2025-445138- DPI-SMP-548 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Eligibility Criteria or specific requirement: Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a procedure. Condition: Eligibility determinations are not reviewed and approved for accuracy of status determination or input into District software. Accordingly, this does not allow for proper segregation of duties for internal control purposes over eligibility compliance requirements. Questioned Costs: None Context: The District has limited employees and does not have adequate segregation of duties over the eligibility process. Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of review. Repeat Finding: 2024-004 Recommendation: We recommend the District designate an individual to review accuracy of status determination and input into software. Views of Responsible Officials: There is no disagreement with the finding.

2025-005 Procurement – Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556 Pass-Through Agency: Wisconsin Department of Instruction Pass Through Numbers: 2025-445138-DPI-SB-546, 2025-445138-DPI-NSL-547, 2025-445138- DPI-SMP-548 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal control over Compliance, Material noncompliance (Qualified 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). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. Additionally supporting documentation regarding the bidding completed by the District’s purchasing cooperative was not obtained for vendor meeting formal procurement threshold per district purchasing policy. Questioned Costs: None Context: During audit testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent used towards the program. In our sample of two transactions subject to small purchase requirements we noted that the District did not retain documentation of an adequate number of price quotes for the one of the two transactions selected for testing. In our sample of one vendor subject to formal procurement threshold we noted that the supporting documentation regarding the bidding completed by the District’s purchasing cooperative was not obtained. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement. Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. Repeat Finding: 2024-005 Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials: There is no disagreement with the finding.

2025-006 Procurement, Suspension & Debarment – Special Education Cluster (IDEA) Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Wisconsin Department of Instruction Pass Through Numbers: 2025-445138-DPI-ES3-342, 2025-445138-DPI-FLOW-341, 2025-445138-DPI-PRESCH-347 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal control over Compliance, Material noncompliance (Qualified 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). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally 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 Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) Context: During our testing of procurement transactions of the program, we noted the District was not consistently following the procurement policy, specifically related to small purchases threshold. In our sample of 3 vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for two vendors. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all four vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement. Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay 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 the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials: There is no disagreement with the finding.