Finding 1168107 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-01-07
Audit: 379850
Organization: Shawano School District (WI)

AI Summary

  • Core Issue: The District lacks a consistent process to verify that vendors are not suspended or debarred, risking compliance with federal regulations.
  • Impacted Requirements: This affects compliance with procurement and suspension/debarment regulations as outlined in 2 CFR 200.214 and 2 CFR part 180.
  • Recommended Follow-Up: The District should review and improve its procedures and ensure grant administrators receive training on federal suspension and debarment regulations.

Finding Text

2025-002 Special Education Cluster: Suspension and Debarment Federal Agency: United States Department of Education Federal program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024/2025-585264-DPI-FLOW-341, 2024/2025-585264-DPI-PRESCH-347 Award Period: 07/01/2024 – 06/30/2025 Compliance Requirements Affected: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing we noted the District does not have a consistent procedure in place for verifying that vendors are not debarred, suspended, or otherwise excluded. Questioned costs: None Context: In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for two of the four vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Effect: The District could contract with a vendor that has been suspended or debarred from receiving Federal Funds. Repeat Finding: 2024-005 Recommendation: We recommend that the District reviews its procedures to ensure the District’s suspension and debarment policy is being consistently followed. We further recommend that the District requires all grant administrators to receive training on Federal suspension and debarment regulations. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

Corrective Action Plan

Special Education Cluster - Suspension and Debarment The finding is a material weakness in internal control over federal awards and material compliance finding due to the District not retaining documentation related to suspension and debarment of vendors. The District will continue to train staff on the District’s procurement policy and the requirement to retain documentation for procurement decisions, including documentation of suspension and debarment verifications.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1168106 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.03M
84.425U ARPA-GENERAL EDUCATION $794,856
93.778 MEDICAL ASSISTANCE PROGRAM $478,833
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $442,118
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $184,916
10.553 SCHOOL BREAKFAST PROGRAM $177,283
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $141,140
10.555 NATIONAL SCHOOL LUNCH PROGRAM $118,168
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $46,886
84.196 EDUCATION FOR HOMELESS CHILDREN AND YOUTH $42,342
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $26,142
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $22,510
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $1,233