Finding 1155759 (2024-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-28

AI Summary

  • Core Issue: The Organization lacks a formal procurement policy and failed to retain necessary documentation for 3 out of 5 transactions, leading to noncompliance with federal regulations.
  • Impacted Requirements: Noncompliance with 2 CFR 200.318 due to exceeding the $10k micro-purchase threshold without adequate documentation.
  • Recommended Follow-Up: Develop a comprehensive procurement policy aligned with Uniform Guidance and ensure proper documentation is maintained for all transactions above the micro-purchase level.

Finding Text

Procurement Policy Federal Agency: U.S. Department of Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Numbers: SLFRP0135-2024 Pass-Through Agency: Wisconsin Department of Workforce Development Pass-Through Number: 7471 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Procurement Type of Finding: Material Weakness in Internal Control over Compliance, Other Matter Criteria or specific requirement: The Organization should have formal procurement policy to guide the Organization when entering into covered transactions. The policy needs to include all components identified in 2 CFR 200.318. The Organization had 3 out of 5 procurements that adequate documentation was not retained to support reaching out to adequate sources. Condition: The Organization had expenses applied to the grant in excess of the $10k required micro-purchase threshold. The Organization also did not have a formal procurement policy in place that follows UG and did not retain supporting documentation to support 3 out of 5 procurement transactions. Questioned Costs: Unknown Context: The Organization entered into transactions in excess of the $10k required micro purchase threshold for which an adequate number of price or rate quotes were not documented. Cause: Management Oversight Repeat Finding: No Effect: The effect of not having a procurement policy with all the required components would be noncompliance with 2 CFR 200.318. Recommendation: It is recommended that the Organization review Uniform Guidance procurement requirements and create a procurement policy to ensure compliance with Uniform Guidance. The Organization should retain supporting documentation for any vendors in excess of the micro purchase level. Views of responsible officials: There is no disagreement with the audit finding. Refer to the Organization’s Corrective Action Plan for more information.

Corrective Action Plan

Procurement Policy Recommendation: We recommend that management and governance review procurement requirements and create a procurement policy as necessary to ensure compliance with Uniform Guidance and retain supporting documentation for any vendors in excess of the micro purchase level. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: WCEDC will develop a procurement policy that is in compliance with Uniform Guidance Name(s) of the contact person(s) responsible for corrective action: Executive Director Jeff Mikorski Planned completion date for corrective action plan: Board approval by February 2026 Board Meeting

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1155758 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $946,600