Audit 45473

FY End
2022-06-30
Total Expended
$922,226
Findings
24
Programs
11
Organization: Port Edwards School District (WI)
Year: 2022 Accepted: 2022-12-20

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
48656 2022-003 Material Weakness - L
48657 2022-006 Material Weakness - P
48658 2022-003 Material Weakness - L
48659 2022-006 Material Weakness - P
48660 2022-003 Material Weakness - L
48661 2022-006 Material Weakness - P
48662 2022-003 Material Weakness - L
48663 2022-006 Material Weakness - P
48664 2022-004 Material Weakness - P
48665 2022-005 Significant Deficiency - N
48666 2022-004 Material Weakness - P
48667 2022-005 Significant Deficiency - N
625098 2022-003 Material Weakness - L
625099 2022-006 Material Weakness - P
625100 2022-003 Material Weakness - L
625101 2022-006 Material Weakness - P
625102 2022-003 Material Weakness - L
625103 2022-006 Material Weakness - P
625104 2022-003 Material Weakness - L
625105 2022-006 Material Weakness - P
625106 2022-004 Material Weakness - P
625107 2022-005 Significant Deficiency - N
625108 2022-004 Material Weakness - P
625109 2022-005 Significant Deficiency - N

Contacts

Name Title Type
XUZ5GM5HW293 Lisa Miller Auditee
7158879000 Amber Danielski, CPA Cma Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the Districts 2022 fund financial statements. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior years ending balances. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedules of expenditures of federal and state awards represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying schedules of expenditures of federal and state awards for the District are presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and the State Single Audit Guidelines issued by the Wisconsin Department of Administration.The schedules of expenditures of federal and state awards include all federal and state awards of the District. Because the schedules present only a selected portion of the operations of the District, it is not intended to and does not present the financial position, changes in net position, or cash flows of the District.
Title: SPECIAL EDUCATION AND SCHOOL AGED PARENTS PROGRAM Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the Districts 2022 fund financial statements. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior years ending balances. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedules of expenditures of federal and state awards represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The 2021 - 2022 eligible costs under the State Special Education Program as reported by the District are $463,186. Compiled information required by compliance requirement 1-1 of the Special Education Audit Program was reported to the Wisconsin Department of Public Instruction.
Title: FOOD DISTRIBUTION Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the Districts 2022 fund financial statements. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior years ending balances. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedules of expenditures of federal and state awards represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Nonmonetary assistance is reported in the schedule of expenditures of federal awards at the fair market value of the commodities received and disbursed.
Title: OVERSIGHT AGENCIES Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the Districts 2022 fund financial statements. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior years ending balances. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedules of expenditures of federal and state awards represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The federal and state oversight agencies for the District are as follows:Federal U.S. Department of EducationState Wisconsin Department of Public Instruction
Title: PASS THROUGH ENTITIES Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the Districts 2022 fund financial statements. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the District in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded District expenditures. Because of subsequent program adjustments, these amounts may differ from the prior years ending balances. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedules of expenditures of federal and state awards represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Federal and state awards have been passed through the following entities:WI DHS - Wisconsin Department of Health ServicesWI DPI - Wisconsin Department of Public InstructionCESA #5 - Cooperative Educational Services Agency #5

Finding Details

Child Nutrition Cluster Reporting Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or specific requirement: Each claim for reimbursement should be based on accurate and precise data. 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 parts of the grant reporting process. Condition: The Food Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster. There is no review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned costs: None. Context: While performing audit procedures, it was noted that the District did not have a review or approval of Child Nutrition claims by someone other than the preparer. Two of the six months tested in our sample had errors in the meal counts reported to Wisconsin Department of Public Instruction. 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 would be under or overpaid for meals due to overclaiming number of meals served. Repeat Finding: No. Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. Questioned costs: None Context: While performing audit procedures, it was noted that when micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. 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. 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 micro purchases, along with adding controls to ensure that the item purchased was received by the District. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Reporting Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or specific requirement: Each claim for reimbursement should be based on accurate and precise data. 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 parts of the grant reporting process. Condition: The Food Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster. There is no review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned costs: None. Context: While performing audit procedures, it was noted that the District did not have a review or approval of Child Nutrition claims by someone other than the preparer. Two of the six months tested in our sample had errors in the meal counts reported to Wisconsin Department of Public Instruction. 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 would be under or overpaid for meals due to overclaiming number of meals served. Repeat Finding: No. Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. Questioned costs: None Context: While performing audit procedures, it was noted that when micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. 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. 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 micro purchases, along with adding controls to ensure that the item purchased was received by the District. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Reporting Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or specific requirement: Each claim for reimbursement should be based on accurate and precise data. 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 parts of the grant reporting process. Condition: The Food Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster. There is no review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned costs: None. Context: While performing audit procedures, it was noted that the District did not have a review or approval of Child Nutrition claims by someone other than the preparer. Two of the six months tested in our sample had errors in the meal counts reported to Wisconsin Department of Public Instruction. 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 would be under or overpaid for meals due to overclaiming number of meals served. Repeat Finding: No. Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. Questioned costs: None Context: While performing audit procedures, it was noted that when micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. 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. 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 micro purchases, along with adding controls to ensure that the item purchased was received by the District. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Reporting Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or specific requirement: Each claim for reimbursement should be based on accurate and precise data. 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 parts of the grant reporting process. Condition: The Food Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster. There is no review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned costs: None. Context: While performing audit procedures, it was noted that the District did not have a review or approval of Child Nutrition claims by someone other than the preparer. Two of the six months tested in our sample had errors in the meal counts reported to Wisconsin Department of Public Instruction. 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 would be under or overpaid for meals due to overclaiming number of meals served. Repeat Finding: No. Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. Questioned costs: None Context: While performing audit procedures, it was noted that when micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. 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. 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 micro purchases, along with adding controls to ensure that the item purchased was received by the District. Views of responsible officials: There is no disagreement with the audit finding.
Elementary and Secondary School Emergency Relief Fund Segregation of Duties Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021 and S425U210044 Federal Award Date 12/6/2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When a transaction does not require a purchase order, there is no formal review and approval by any District employee other than the Business Director to ensure the activity and cost is allowable under the grant. There is no separate review of the payroll transactions processed by the Business Director and subsequently included on the grant claims. Questioned costs: None Context: While performing audit procedures, it was noted that when transactions did not require a purchase order, the transaction was compared to the approved grant budget by the Business Director but there was no other review by the Superintendent or other positions responsible for the grant activity prior to payment. It was also noted that there was no review of the payroll costs reported on the grant claims or labor distribution reports to ensure only the proper employees and related costs were coded to grant. 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. 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 when purchase orders are not required, along with adding controls to ensure that the item purchased was received by the District. We also recommend the District review its payroll process and identify payroll tasks that could be reassigned to other district personnel or consider implementing additional review procedures specifically focused on payroll and related fringe benefit costs claimed on federal and state grants. Views of responsible officials: There is no disagreement with the audit finding.
Elementary and Secondary School Emergency Relief Fund Wage Rate Requirements Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021 and S425U210044 Federal Award Date 12/6/2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The District is responsible for ensuring the contractor provides the appropriate certified payrolls and reviewing them to ensure the prevailing wage rates are being met or exceeded. The District contracted with a third party to provide construction management including reviewing for Davis Bacon compliance; however, the District did not implement controls to monitor the construction management company to ensure this compliance requirement was met. Questioned costs: None. Context: While performing audit procedures, it was noted that the District's construction manager did obtain and review the appropriate certified payrolls; however, the District did not implement controls to monitor the construction manager to ensure this compliance requirement was met. Cause: The District was aware of the Davis Bacon Act and the compliance requirements surrounding it; however, the District was not aware they needed to document controls ensuring this was completed Effect: The District could pay vendors that are not in compliance with the Davis Bacon requirements. Repeat Finding: No. Recommendation: We recommended the District implement controls for monitoring third party contractors when the contractors are responsible for compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.
Elementary and Secondary School Emergency Relief Fund Segregation of Duties Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021 and S425U210044 Federal Award Date 12/6/2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When a transaction does not require a purchase order, there is no formal review and approval by any District employee other than the Business Director to ensure the activity and cost is allowable under the grant. There is no separate review of the payroll transactions processed by the Business Director and subsequently included on the grant claims. Questioned costs: None Context: While performing audit procedures, it was noted that when transactions did not require a purchase order, the transaction was compared to the approved grant budget by the Business Director but there was no other review by the Superintendent or other positions responsible for the grant activity prior to payment. It was also noted that there was no review of the payroll costs reported on the grant claims or labor distribution reports to ensure only the proper employees and related costs were coded to grant. 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. 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 when purchase orders are not required, along with adding controls to ensure that the item purchased was received by the District. We also recommend the District review its payroll process and identify payroll tasks that could be reassigned to other district personnel or consider implementing additional review procedures specifically focused on payroll and related fringe benefit costs claimed on federal and state grants. Views of responsible officials: There is no disagreement with the audit finding.
Elementary and Secondary School Emergency Relief Fund Wage Rate Requirements Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021 and S425U210044 Federal Award Date 12/6/2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The District is responsible for ensuring the contractor provides the appropriate certified payrolls and reviewing them to ensure the prevailing wage rates are being met or exceeded. The District contracted with a third party to provide construction management including reviewing for Davis Bacon compliance; however, the District did not implement controls to monitor the construction management company to ensure this compliance requirement was met. Questioned costs: None. Context: While performing audit procedures, it was noted that the District's construction manager did obtain and review the appropriate certified payrolls; however, the District did not implement controls to monitor the construction manager to ensure this compliance requirement was met. Cause: The District was aware of the Davis Bacon Act and the compliance requirements surrounding it; however, the District was not aware they needed to document controls ensuring this was completed Effect: The District could pay vendors that are not in compliance with the Davis Bacon requirements. Repeat Finding: No. Recommendation: We recommended the District implement controls for monitoring third party contractors when the contractors are responsible for compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Reporting Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or specific requirement: Each claim for reimbursement should be based on accurate and precise data. 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 parts of the grant reporting process. Condition: The Food Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster. There is no review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned costs: None. Context: While performing audit procedures, it was noted that the District did not have a review or approval of Child Nutrition claims by someone other than the preparer. Two of the six months tested in our sample had errors in the meal counts reported to Wisconsin Department of Public Instruction. 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 would be under or overpaid for meals due to overclaiming number of meals served. Repeat Finding: No. Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. Questioned costs: None Context: While performing audit procedures, it was noted that when micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. 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. 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 micro purchases, along with adding controls to ensure that the item purchased was received by the District. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Reporting Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or specific requirement: Each claim for reimbursement should be based on accurate and precise data. 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 parts of the grant reporting process. Condition: The Food Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster. There is no review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned costs: None. Context: While performing audit procedures, it was noted that the District did not have a review or approval of Child Nutrition claims by someone other than the preparer. Two of the six months tested in our sample had errors in the meal counts reported to Wisconsin Department of Public Instruction. 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 would be under or overpaid for meals due to overclaiming number of meals served. Repeat Finding: No. Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. Questioned costs: None Context: While performing audit procedures, it was noted that when micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. 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. 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 micro purchases, along with adding controls to ensure that the item purchased was received by the District. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Reporting Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or specific requirement: Each claim for reimbursement should be based on accurate and precise data. 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 parts of the grant reporting process. Condition: The Food Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster. There is no review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned costs: None. Context: While performing audit procedures, it was noted that the District did not have a review or approval of Child Nutrition claims by someone other than the preparer. Two of the six months tested in our sample had errors in the meal counts reported to Wisconsin Department of Public Instruction. 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 would be under or overpaid for meals due to overclaiming number of meals served. Repeat Finding: No. Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. Questioned costs: None Context: While performing audit procedures, it was noted that when micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. 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. 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 micro purchases, along with adding controls to ensure that the item purchased was received by the District. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Reporting Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or specific requirement: Each claim for reimbursement should be based on accurate and precise data. 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 parts of the grant reporting process. Condition: The Food Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster. There is no review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned costs: None. Context: While performing audit procedures, it was noted that the District did not have a review or approval of Child Nutrition claims by someone other than the preparer. Two of the six months tested in our sample had errors in the meal counts reported to Wisconsin Department of Public Instruction. 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 would be under or overpaid for meals due to overclaiming number of meals served. Repeat Finding: No. Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Views of responsible officials: There is no disagreement with the audit finding.
Child Nutrition Cluster Procurement Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-SB-SEVERE-546, 2022-714508-DPI-NSL-547, 2021-714508-DPI-SFSP-566 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. Questioned costs: None Context: While performing audit procedures, it was noted that when micro purchase transactions did not require a purchase order, there was no documented review by the Superintendent or other positions responsible for the grant activity prior to payment to ensure allowability and proper coding. 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. 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 micro purchases, along with adding controls to ensure that the item purchased was received by the District. Views of responsible officials: There is no disagreement with the audit finding.
Elementary and Secondary School Emergency Relief Fund Segregation of Duties Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021 and S425U210044 Federal Award Date 12/6/2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When a transaction does not require a purchase order, there is no formal review and approval by any District employee other than the Business Director to ensure the activity and cost is allowable under the grant. There is no separate review of the payroll transactions processed by the Business Director and subsequently included on the grant claims. Questioned costs: None Context: While performing audit procedures, it was noted that when transactions did not require a purchase order, the transaction was compared to the approved grant budget by the Business Director but there was no other review by the Superintendent or other positions responsible for the grant activity prior to payment. It was also noted that there was no review of the payroll costs reported on the grant claims or labor distribution reports to ensure only the proper employees and related costs were coded to grant. 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. 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 when purchase orders are not required, along with adding controls to ensure that the item purchased was received by the District. We also recommend the District review its payroll process and identify payroll tasks that could be reassigned to other district personnel or consider implementing additional review procedures specifically focused on payroll and related fringe benefit costs claimed on federal and state grants. Views of responsible officials: There is no disagreement with the audit finding.
Elementary and Secondary School Emergency Relief Fund Wage Rate Requirements Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021 and S425U210044 Federal Award Date 12/6/2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The District is responsible for ensuring the contractor provides the appropriate certified payrolls and reviewing them to ensure the prevailing wage rates are being met or exceeded. The District contracted with a third party to provide construction management including reviewing for Davis Bacon compliance; however, the District did not implement controls to monitor the construction management company to ensure this compliance requirement was met. Questioned costs: None. Context: While performing audit procedures, it was noted that the District's construction manager did obtain and review the appropriate certified payrolls; however, the District did not implement controls to monitor the construction manager to ensure this compliance requirement was met. Cause: The District was aware of the Davis Bacon Act and the compliance requirements surrounding it; however, the District was not aware they needed to document controls ensuring this was completed Effect: The District could pay vendors that are not in compliance with the Davis Bacon requirements. Repeat Finding: No. Recommendation: We recommended the District implement controls for monitoring third party contractors when the contractors are responsible for compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.
Elementary and Secondary School Emergency Relief Fund Segregation of Duties Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021 and S425U210044 Federal Award Date 12/6/2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance 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 transaction. Condition: When a transaction does not require a purchase order, there is no formal review and approval by any District employee other than the Business Director to ensure the activity and cost is allowable under the grant. There is no separate review of the payroll transactions processed by the Business Director and subsequently included on the grant claims. Questioned costs: None Context: While performing audit procedures, it was noted that when transactions did not require a purchase order, the transaction was compared to the approved grant budget by the Business Director but there was no other review by the Superintendent or other positions responsible for the grant activity prior to payment. It was also noted that there was no review of the payroll costs reported on the grant claims or labor distribution reports to ensure only the proper employees and related costs were coded to grant. 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. 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 when purchase orders are not required, along with adding controls to ensure that the item purchased was received by the District. We also recommend the District review its payroll process and identify payroll tasks that could be reassigned to other district personnel or consider implementing additional review procedures specifically focused on payroll and related fringe benefit costs claimed on federal and state grants. Views of responsible officials: There is no disagreement with the audit finding.
Elementary and Secondary School Emergency Relief Fund Wage Rate Requirements Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021 and S425U210044 Federal Award Date 12/6/2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The District is responsible for ensuring the contractor provides the appropriate certified payrolls and reviewing them to ensure the prevailing wage rates are being met or exceeded. The District contracted with a third party to provide construction management including reviewing for Davis Bacon compliance; however, the District did not implement controls to monitor the construction management company to ensure this compliance requirement was met. Questioned costs: None. Context: While performing audit procedures, it was noted that the District's construction manager did obtain and review the appropriate certified payrolls; however, the District did not implement controls to monitor the construction manager to ensure this compliance requirement was met. Cause: The District was aware of the Davis Bacon Act and the compliance requirements surrounding it; however, the District was not aware they needed to document controls ensuring this was completed Effect: The District could pay vendors that are not in compliance with the Davis Bacon requirements. Repeat Finding: No. Recommendation: We recommended the District implement controls for monitoring third party contractors when the contractors are responsible for compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.