Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) Assistance Listing Number: 10.553, 10.555, and 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2025-105726-DPI-SB-SEVERE-546, 2025-105726-DPI-SK_NSLAE-566, 2025-105726-DPI-NSL-547, 2025-105726-DPI-SFSP-586 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: Federal regulations require that school districts maintain accurate and complete eligibility documentation for all students receiving free or reduced-price meals. Benefits must be discontinued promptly when students are no longer eligible, and direct certification listings must be updated annually to ensure only eligible students receive benefits. Condition: There is no formal, documented process in place to ensure accurate eligibility determinations and maintenance of benefit issuance listings for the Child Nutrition Cluster. During testing, it was noted that during the transition period when the food service director left early in fiscal year 2024–2025, there was a substantial loss of records, including student applications. Additionally, the prior Food Service Director did not clear out old certifications of eligibility in the software used for food service record keeping, which caused students who had previously applied for free or reduced-price meals to continue receiving benefits regardless of whether a new application was filed or whether they appeared on the current direct certification list. Students with approval dates dating back to 2012 were noted on the benefit issuance list. There was no formal documented review and approval of eligibility determinations by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned Costs: Unable to be determined. Context: When performing audit procedures related to eligibility for the Child Nutrition Cluster, it was noted that the District did not maintain adequate documentation or controls to ensure proper eligibility determinations. Four applications in our sample of seventy students were unable to be located. Six students in our sample of seventy students were actually no longer with the District. No meals were claimed for those six students. Ten students in our sample of seventy students were no longer eligible for benefits via direct certification yet still received benefits for part or all of the school year. Twenty-two students in our sample of seventy students were no longer eligible for benefits via direct certification but had no meals claimed in 2024-25. Cause: The errors occurred due to inadequate internal controls over eligibility determinations and record retention. Contributing factors include staff turnover, data loss when position turned over, and lack of formal procedures to ensure timely updates to eligibility listings. Effect: Improper benefits were provided to students who were not eligible, and reimbursement claims were submitted for meals that should not have been claimed. This could result in questioned costs and noncompliance with federal program requirements. Repeat Finding: No Recommendation: We recommend that the District implement formal procedures to strengthen controls over eligibility determinations. These procedures should include ensuring timely updates to eligibility listings when students become ineligible, retaining all required documentation for the applicable retention period, and conducting periodic reviews of benefit issuance listings to confirm accuracy. Additionally, auditors recommend the District implement procedures to ensure staff receive training on proper eligibility determination and recordkeeping requirements. Finally, we recommend the District establish monitoring controls to verify that benefits are discontinued promptly for students who no longer qualify. Eligibility determinations should be reviewed and approved by someone other than the person entering the applications and direct certification information into the software. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) Assistance Listing Number: 10.553, 10.555, and 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2025-105726-DPI-SB-SEVERE-546, 2025-105726-DPI-SK_NSLAE-566, 2025-105726-DPI-NSL-547, 2025-105726-DPI-SFSP-586 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200.303 requires grantees to establish, document, and maintain effective internal control over federal awards that provides reasonable assurance that the grantee is managing the federal in compliance with federal statutes, regulations, and the terms and conditions of federal award. This includes internal controls over the procurement transactions and verifying suspension and debarment status of vendors when required. 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 transaction. Condition: There is not a formal, documented review in place for procurement transactions related to micro purchases or food service contracts. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When performing audit procedures related to procurement, and suspension and debarment, it was noted that the food service director position handled all the responsibilities of those functions related to Child Nutrition Cluster and there were no formal, documented internal controls over compliance in place to review that procurement transactions met Uniform Guidance requirements and were properly documented. 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 segregation of duties. The District could chose the incorrect procurement method for a transaction and fail to maintain all required documentation resulting in noncompliance. The District could award contracts to vendors who are suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: No. Recommendation: We recommend the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving all procurement transactions. We also recommend that the District review and update policies and procedures to help ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction and that documentation of the status is maintained with the procurement history of each transaction that it is required for. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) Assistance Listing Number: 10.553, 10.555, and 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2025-105726-DPI-SB-SEVERE-546, 2025-105726-DPI-SK_NSLAE-566, 2025-105726-DPI-NSL-547, 2025-105726-DPI-SFSP-586 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or specific requirement: Each request for reimbursement should be based on accurate and precise data. Review of the reimbursement request and supporting documentation by someone other than the preparer prior to submitting the request for reimbursement is an internal control intended to prevent or decrease the occurrence of errors. Condition: During testing of the September Breakfast claim, it was noted that the total meal count was correct; however, the categories under which the meals were claimed were incorrect. Specifically, the claim report showed variances between the reported and actual counts for free, reduced, and paid meals, resulting in an overclaim. There was no documented review and approval of the claim by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned costs: $467 Context: One of the six claims in our sample included overcharges due to claiming charged meals or mistyping a number into the report for reimbursement. Cause: There was turnover in the Food Service Director position and the absence of a designated person to prepare the claim at the time of submission. The lack of formalized procedures for claim review and record retention contributed to the error. Effect: The District was overpaid for meals due to overclaiming number of meals served. Repeat Finding: No Recommendation: We recommend that the District review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is different from the individual responsible for preparing, even when there are gaps of coverage in preparer and reviewer positions, and that the review and approval happens prior to submitting the reports to the granting agency. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Title I Grants to Educational Agencies Assistance Listing Number: 84.010 Federal Award Identification Number and Year: S010A240049 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2025-105726-DPI-TI-A-141 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200.303 requires grantees to establish, document, and maintain effective internal control over federal awards that provides reasonable assurance that the grantee is managing the federal in compliance with federal statutes, regulations, and the terms and conditions of federal award. This includes implementing controls for verifying only allowable costs are recorded and eligibility determinations are properly documented and reviewed by someone other than the preparer. 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 transaction. Condition: There is no formal, documented review and approval by any District employee to ensure the activity and cost is allowable under the grant. There is also no formal documented review and approval of the eligibility forms filed in Wisegrants. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to allowable costs, it was noted that the Bookkeeper or District Office Manager position handled all the responsibilities of those functions related to Title I and there were no formal, documented internal controls over compliance in place to review that costs met all requirements and were properly documented. There was no review of the work completed by someone other than the preparer. While the District met with CESA 10 to review the eligibility reports, there was no formal review or approval of the reports submitted in Wisegrants. 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 segregation of duties. Unallowable costs could be recorded for the grant resulting in noncompliance. Eligibility determinations could be incorrect, resulting in noncompliance. Repeat Finding: No. Recommendation: We recommend the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving purchases, along with adding controls to ensure that the item purchased was received by the District. We also recommend the District printout the eligibility reports from Wisegrants and sign and date them to indicate review and approval after meeting with CESA 10 each year. Views of Responsible Officials: There is no disagreement with the audit finding.