Finding 1155465 (2024-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-26

AI Summary

  • Core Issue: The Organization failed to create a written contract with a contractor that includes required provisions, leading to potential misuse of Federal Award funds.
  • Impacted Requirements: Noncompliance with 2 CFR§200.201(a), 2 CFR§200.327, and 2 CFR§200.303 regarding contract provisions and internal controls over procurement.
  • Recommended Follow-Up: Management should enhance monitoring of procurement procedures and ensure compliance with contracting requirements; a third-party review of the fiscal policy manual is also planned.

Finding Text

Noncompliance with Contract Provisions for Non-Federal Entity Contracts Under Federal Awards and Material Weakness in Internal Control over Procurement and Suspension and Debarment Assistance Listing Number: 10.561 Name of Federal Program or Cluster: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (SNAP Cluster) Name of Federal Agency: Department of Agriculture Name of Pass-Through Entities: State of Wisconsin Department of Health Services passed through Dane County Procurement and Suspension and Debarment 2 CFR§200.201(a) requires a pass-through entity must decide on the appropriate type of agreement for a Federal award (for example, a grant, cooperative agreements, subaward, or contract). 2 CFR§200.327 contract provisions requires the recipients or subrecipient contracts must contain the applicable provisions described in Appendix II of the Uniform Guidance. Appendix II Part 200-Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires all contracts made by the non-Federal entity under the Federal award must contain the provisions listed in the section as applicable. 2 CFR§200.303 requires the Organization to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Organization did not create a written contract with one of its contractors that contains the required contractual provisions listed in the criteria. In addition, the Organization’s internal controls over procurement did not prevent or detect noncompliance with the applicable requirements.Cause: The Organization has policies and procedures related to procurement in its fiscal procedures manual. However, management did not monitor to ensure that the applicable policies and procedures were being followed. Failure to enter into the required contracts that contain the applicable contractual provisions could lead the Organization to inappropriately disburse Federal Award funds to contractors. We recommend that Organization management monitor compliance with procurement procedures to ensure that the required contracting is occurring. No WRTP has reviewed the organization’s fiscal policy manual including all subsections regarding contractual provisions and procurement. Additional training has been provided and completed by management and staff. The fiscal policy manual procurement section will undergo further review by a third party and if recommended, will be updated and presented to the Finance Committee of the Board of Directors.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1155462 2024-002
    Material Weakness Repeat
  • 1155463 2024-002
    Material Weakness Repeat
  • 1155464 2024-002
    Material Weakness Repeat
  • 1155466 2024-003
    Material Weakness Repeat
  • 1155467 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
17.274 Youthbuild $167,214
17.268 H-1b Job Training Grants $131,218
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $124,916
47.084 Nsf Technology, Innovation, and Partnerships $96,436
81.086 Conservation Research and Development $45,742
20.205 Highway Planning and Construction $28,783
21.027 Coronavirus State and Local Fiscal Recovery Funds $25,233
14.218 Community Development Block Grants/entitlement Grants $25,000
84.002 Adult Education - Basic Grants to States $23,704