FAC Explorer

Audit 6757

FY End
2023-06-30
Total Expended
$954,989
Findings
14
Programs
15
Organization: Pittsville School District (WI)
Year: 2023 Accepted: 2023-12-14
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
4339 2023-003 Significant Deficiency - I
4340 2023-003 Significant Deficiency - I
4341 2023-003 Significant Deficiency - I
4342 2023-003 Significant Deficiency - I
4343 2023-003 Significant Deficiency - I
4344 2023-004 Material Weakness - P
4345 2023-004 Material Weakness - P
580781 2023-003 Significant Deficiency - I
580782 2023-003 Significant Deficiency - I
580783 2023-003 Significant Deficiency - I
580784 2023-003 Significant Deficiency - I
580785 2023-003 Significant Deficiency - I
580786 2023-004 Material Weakness - P
580787 2023-004 Material Weakness - P

Programs

ALN Program Spent Major Findings
84.425 Education Stabilization Fund $165,544 Yes 1
84.027 Special Education_grants to States $128,746 - 0
84.010 Title I Grants to Local Educational Agencies $77,707 - 0
10.553 School Breakfast Program $74,660 Yes 1
93.778 Medical Assistance Program $73,272 - 0
10.559 Summer Food Service Program for Children $42,287 Yes 1
84.358 Rural Education $40,126 - 0
32.009 Emergency Connectivity Fund Program $34,935 - 0
10.555 National School Lunch Program $24,891 Yes 1
84.367 Improving Teacher Quality State Grants $13,333 - 0
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $10,085 - 0
84.424 Student Support and Academic Enrichment Program $10,000 - 0
84.173 Special Education_preschool Grants $6,978 - 0
93.724 Arra - Prevention and Wellness Ð Communities Putting Prevention to Work Funding Opportunities Announcement (foa) $2,073 - 0
84.048 Career and Technical Education -- Basic Grants to States $1,400 - 0

Contacts

Name Title Type
C7NCZ3XBNGH1 Pamela J. Tesch, Ea, Csrm Auditee
7158846694 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 District’s 2023 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 year’s ending balances. Expenditures on the schedules are recognized following the cost principles contained in the Uniform Guidance and the State Single Audit Guidelines, 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 District has not elected to charge a de minimis rate of 10% of modified total costs. 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: 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 District’s 2023 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 year’s ending balances. Expenditures on the schedules are recognized following the cost principles contained in the Uniform Guidance and the State Single Audit Guidelines, 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 District has not elected to charge a de minimis rate of 10% of modified total costs. 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 District’s 2023 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 year’s ending balances. Expenditures on the schedules are recognized following the cost principles contained in the Uniform Guidance and the State Single Audit Guidelines, 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 District has not elected to charge a de minimis rate of 10% of modified total costs. The federal and state oversight agencies for the District are as follows: Federal – U.S. Department of Education State – 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 District’s 2023 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 year’s ending balances. Expenditures on the schedules are recognized following the cost principles contained in the Uniform Guidance and the State Single Audit Guidelines, 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 District has not elected to charge a de minimis rate of 10% of modified total costs. Federal and state awards have been passed through the following entities: WI DPI – Wisconsin Department of Public Instruction CESA #5 – Cooperative Educational Service Agency No. #5 MSTC – Mid-State Technical College

Finding Details

Finding 2023-003
Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-003
Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-003
Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-003
Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-003
Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-004
Federal Agency: US Department of Education Federal Program Name: Elementary and Secondary School Emergency Relief Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425U210044 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-714368-DPI-ESSERFII-163, 2022-714368-DPI-ESSERFIII-165 Award Period: 3/13/2020-9/30/2024 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 detect the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction. Condition: The director of business services has the capability of doing all functions of the general disbursement and payroll processes. There is a bookkeeper that helps with some of the steps in these processes, but the bookkeeper is part-time and the director of business services will complete these tasks in her absence. The director of business services prepared the annual report and there was no review of the report by someone other than the preparer prior to submission to Wisconsin Department of Public instruction. 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 reporting (annual report) and allowable costs and allowable activities (general disbursements and payroll), it was noted that the director of business services position handled all the responsibilities of those functions and there were no formal, documented internal controls over compliance in place to review that procedures were performed as required and no review of the work completed by someone other than the preparer. 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. District could incorrectly report amounts and other data on the annual report. Repeat Finding: No. Recommendation: We recommend the District review its processes related to general disbursements for grants and implement a control where someone other than the director of business services is reviewing disbursements coded to grant project codes to help ensure compliance with grant requirements. For payroll transactions, we recommend implementing a control where someone other than the director of business services is reviewing who is coded to the grant on a routine basis and that the payroll allocation to the grant is appropriate and supported by time and effort documentation. We also recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-004
Federal Agency: US Department of Education Federal Program Name: Elementary and Secondary School Emergency Relief Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425U210044 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-714368-DPI-ESSERFII-163, 2022-714368-DPI-ESSERFIII-165 Award Period: 3/13/2020-9/30/2024 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 detect the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction. Condition: The director of business services has the capability of doing all functions of the general disbursement and payroll processes. There is a bookkeeper that helps with some of the steps in these processes, but the bookkeeper is part-time and the director of business services will complete these tasks in her absence. The director of business services prepared the annual report and there was no review of the report by someone other than the preparer prior to submission to Wisconsin Department of Public instruction. 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 reporting (annual report) and allowable costs and allowable activities (general disbursements and payroll), it was noted that the director of business services position handled all the responsibilities of those functions and there were no formal, documented internal controls over compliance in place to review that procedures were performed as required and no review of the work completed by someone other than the preparer. 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. District could incorrectly report amounts and other data on the annual report. Repeat Finding: No. Recommendation: We recommend the District review its processes related to general disbursements for grants and implement a control where someone other than the director of business services is reviewing disbursements coded to grant project codes to help ensure compliance with grant requirements. For payroll transactions, we recommend implementing a control where someone other than the director of business services is reviewing who is coded to the grant on a routine basis and that the payroll allocation to the grant is appropriate and supported by time and effort documentation. We also recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-003
Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-003
Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-003
Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-003
Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-003
Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-004
Federal Agency: US Department of Education Federal Program Name: Elementary and Secondary School Emergency Relief Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425U210044 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-714368-DPI-ESSERFII-163, 2022-714368-DPI-ESSERFIII-165 Award Period: 3/13/2020-9/30/2024 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 detect the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction. Condition: The director of business services has the capability of doing all functions of the general disbursement and payroll processes. There is a bookkeeper that helps with some of the steps in these processes, but the bookkeeper is part-time and the director of business services will complete these tasks in her absence. The director of business services prepared the annual report and there was no review of the report by someone other than the preparer prior to submission to Wisconsin Department of Public instruction. 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 reporting (annual report) and allowable costs and allowable activities (general disbursements and payroll), it was noted that the director of business services position handled all the responsibilities of those functions and there were no formal, documented internal controls over compliance in place to review that procedures were performed as required and no review of the work completed by someone other than the preparer. 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. District could incorrectly report amounts and other data on the annual report. Repeat Finding: No. Recommendation: We recommend the District review its processes related to general disbursements for grants and implement a control where someone other than the director of business services is reviewing disbursements coded to grant project codes to help ensure compliance with grant requirements. For payroll transactions, we recommend implementing a control where someone other than the director of business services is reviewing who is coded to the grant on a routine basis and that the payroll allocation to the grant is appropriate and supported by time and effort documentation. We also recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports. View of Responsible Officials: There is no disagreement with the audit finding.
Finding 2023-004
Federal Agency: US Department of Education Federal Program Name: Elementary and Secondary School Emergency Relief Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425U210044 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-714368-DPI-ESSERFII-163, 2022-714368-DPI-ESSERFIII-165 Award Period: 3/13/2020-9/30/2024 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 detect the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction. Condition: The director of business services has the capability of doing all functions of the general disbursement and payroll processes. There is a bookkeeper that helps with some of the steps in these processes, but the bookkeeper is part-time and the director of business services will complete these tasks in her absence. The director of business services prepared the annual report and there was no review of the report by someone other than the preparer prior to submission to Wisconsin Department of Public instruction. 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 reporting (annual report) and allowable costs and allowable activities (general disbursements and payroll), it was noted that the director of business services position handled all the responsibilities of those functions and there were no formal, documented internal controls over compliance in place to review that procedures were performed as required and no review of the work completed by someone other than the preparer. 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. District could incorrectly report amounts and other data on the annual report. Repeat Finding: No. Recommendation: We recommend the District review its processes related to general disbursements for grants and implement a control where someone other than the director of business services is reviewing disbursements coded to grant project codes to help ensure compliance with grant requirements. For payroll transactions, we recommend implementing a control where someone other than the director of business services is reviewing who is coded to the grant on a routine basis and that the payroll allocation to the grant is appropriate and supported by time and effort documentation. We also recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports. View of Responsible Officials: There is no disagreement with the audit finding.