Finding Text
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, S425U210044 Federal Award Date 12/6/2021 and 3/13/2020
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165, 2024-714508-DPI-LETRS-165
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter
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.