Audit 390240

2025-003 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 Pass-Through Agency: Wisconsin Department of Instruction Pass Through Numbers: 2025-133675-DPI-SB-546, 2024-133675-DPI-NSL-547 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Reporting 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: The monthly claim forms submitted by the District are prepared and submitted by one individual. Accordingly, this does not allow for proper segregation of duties. Questioned Costs: None Context: The District has limited program 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 program 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: No Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Views of Responsible Officials: There is no disagreement with the finding.

2025-004 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: 2025-133675-DPI-FLOW-341, 2025-133675-DPI-PRESCH-347 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Suspension and Debarment Criteria or specific requirement: 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 did not retain documentation of verification that that vendors are not debarred, suspended or otherwise excluded. Questioned Costs: None Context: In sample of 5 vendors contracts subject to suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all vendors that were selected for testing. Cause: The District did not retain documentation following their Federal Funds Procurement policy related to the appropriate methods of procurement. Effect: 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 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.