Finding #2023-002 – #84.425D COVID-19 Elementary and Secondary School Emergency Relief Fund II Federal Grantor: U.S. Department of Education
Pass-through Award Number: 2022-131309-DPI-ESSERFII-163
Pass-through Entity: Wisconsin Department of Public Instruction
Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborer must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL).
Nonfederal entities shall include in their contracts subject to wage rate requirements a provision that the contractor or subcontractor complies with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Condition: There was one Education Stabilization Fund construction project performed by a subcontractor. Grant expenditures for the project paid by the Education Stabilization Fund totaled $34,828. There was not a prevailing wage clause in the contract and certified payrolls were not received.
Cause: The District was not aware that wage rate requirements applied to the construction project until after it was completed.
Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements.
Questioned Costs: $34,828.
Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Consider determining if the contractor performing the project in 2022-2023 paid prevailing wage rates for costs reimbursed by the grant. Otherwise, the District should replace the cost with other allowable costs.
Response: The District replaced the cost with other allowable costs.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-002 – #84.425D COVID-19 Elementary and Secondary School Emergency Relief Fund II Federal Grantor: U.S. Department of Education
Pass-through Award Number: 2022-131309-DPI-ESSERFII-163
Pass-through Entity: Wisconsin Department of Public Instruction
Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborer must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL).
Nonfederal entities shall include in their contracts subject to wage rate requirements a provision that the contractor or subcontractor complies with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Condition: There was one Education Stabilization Fund construction project performed by a subcontractor. Grant expenditures for the project paid by the Education Stabilization Fund totaled $34,828. There was not a prevailing wage clause in the contract and certified payrolls were not received.
Cause: The District was not aware that wage rate requirements applied to the construction project until after it was completed.
Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements.
Questioned Costs: $34,828.
Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Consider determining if the contractor performing the project in 2022-2023 paid prevailing wage rates for costs reimbursed by the grant. Otherwise, the District should replace the cost with other allowable costs.
Response: The District replaced the cost with other allowable costs.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.
Finding #2023-001 – Lack of Segregation of Duties
Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances.
Condition: The responsibility for the District’s bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts.
Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources.
Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis.
Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances.
Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District’s finances. The Superintendent is not involved in processing day to day financial transactions.