Finding 1164684 (2025-001)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
$1
Year
2025
Accepted
2025-12-12

AI Summary

  • Core Issue: The District improperly charged payroll costs to both the Medicaid program and another federal program, leading to duplicate reimbursements.
  • Impacted Requirements: This practice violates federal regulations (2 CFR 200.403 and 2 CFR 200.405) that require costs to be allocated to a single federal award.
  • Recommended Follow-Up: Strengthen internal controls by updating the Skyward Qmlative system settings and implementing detailed quarterly reviews to prevent future duplicate charges.

Finding Text

Program Name: 93.778 Medicaid Cluster Description: Unallowable Costs and Reporting Condition and Criteria: The District charged payroll costs to the Medicaid program that were also charged to another federal program (IDEA Flow-Through), resulting in duplicate federal reimbursement for the same expenditures (“double-dipping”). Under 2 CFR 200.403 and 2 CFR 200.405, costs must be allocable to a single federal award and must not be charged to multiple programs. During audit testing of payroll charges, we identified employees whose salaries were allocated to both the Medicaid and IDEA Flow-Through programs for overlapping pay periods. Effect: The District’s internal controls failed to prevent or detect duplicate charges of federal payroll costs, resulting in noncompliance with federal cost principles and inaccurate Medicaid claiming. Cause: The condition resulted from control deficiencies in the District’s implementation of the new Skyward “Qmlative” accounting system. Specifically, the District did not select a configuration setting (“cross-reference other federal codes”) necessary to prevent duplicate allocations when importing payroll data for Medicaid claiming. Additionally, the District’s quarterly payroll review procedures focused on verifying employee totals rather than reconciling detailed payroll allocations across federal programs, which contributed to the oversight. Questioned Costs: $345,925 (projected) Auditors’ Recommendation: We recommend that the District strengthen internal controls over payroll cost allocation and Medicaid claiming to ensure that costs are charged to only one federal program. Specifically, the District should review and update the Skyward Qmlative configuration to properly identify and exclude payroll costs already charged to other federal projects, and implement detailed quarterly review procedures to verify that payroll data reconciles across all federal program codes. Views of Responsible Officials and Corrective Action Plan: See attachment for District’s corrective action plan.

Corrective Action Plan

Reference Number: 2025-001 Description: Finding 2025-001 - Federal ALN 93.778 Medicaid Cluster Corrective Action Plan: The District will update the setup for Medicaid reporting in Skyward Qmlativ to back out expenditures coded to federal grants, specifically project numbers 341 and 347. Anticipated Corrective Action Plan Completion Date: Corrective action was implemented on July 23, 2025. The district has reviewed reports generated after this date and verified the accuracy of reporting. Contact Information: For additional information regarding this finding please contact Beth Sheridan, Assistant Superintendent of Finance and Operations, at 262-560-2119. Beth Sheridan Assistant Superintendent of Finance and Operations

Categories

Questioned Costs Allowable Costs / Cost Principles

Programs in Audit

ALN Program Name Expenditures
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.14M
93.778 MEDICAL ASSISTANCE PROGRAM $468,442
10.555 NATIONAL SCHOOL LUNCH PROGRAM $360,444
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $190,036
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $70,455
10.553 SCHOOL BREAKFAST PROGRAM $45,244
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $28,763
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $24,830
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $18,202
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $7,594
84.425 EDUCATION STABILIZATION FUND $3,711