Finding Text
Suspension & Debarment Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (Special Education – Grants to States and Special Education – Preschool Grants) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A240064 and H173A240070 Pass- through Agency: Wisconsin Department of Public Instruction Pass-through Numbers: 2025 - 495607 - DPI - FLOW – 341 and 2025 - 495607 - DPI - PRESCH - 347 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Requirement: Procurement, Suspension & Debarment Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition: The District entered into procurement transactions that exceeded the covered threshold and while the District did perform a review of suspension and debarment status using sam.gov, it did not document that the review was completed prior to entering the contract or approving the procurement transaction in accordance with 2 CFR section 180.220. Questioned Costs: None Context: The District did not document the date of the suspension and debarment review for the three transactions that exceeded the covered threshold during the year. Cause: The District did not have procedures in place to help ensure that the date of review was documented. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: No Recommendation: We recommend the District revise its policies and procedures to ensure that documentation as to the date of the review of suspension and debarment status is maintained with the procurement history of each transaction that requires such a search. Views of Responsible Officials: There is no disagreement with the finding.