Finding 1169102 (2025-004)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-01-15

AI Summary

  • Core Issue: The District lacks proper segregation of duties in the eligibility process, increasing the risk of errors or fraud.
  • Impacted Requirements: Internal controls over eligibility compliance are insufficient due to unreviewed status determinations.
  • Recommended Follow-Up: Designate a specific individual to review and approve eligibility determinations and software inputs.

Finding Text

2025-004 Segregation of Duties – Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556 Pass-Through Agency: Wisconsin Department of Instruction Pass Through Numbers: 2025-445138-DPI-SB-546, 2025-445138-DPI-NSL-547, 2025-445138- DPI-SMP-548 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Eligibility Criteria or specific requirement: Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a procedure. Condition: Eligibility determinations are not reviewed and approved for accuracy of status determination or input into District software. Accordingly, this does not allow for proper segregation of duties for internal control purposes over eligibility compliance requirements. Questioned Costs: None Context: The District has limited employees and does not have adequate segregation of duties over the eligibility process. Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of review. Repeat Finding: 2024-004 Recommendation: We recommend the District designate an individual to review accuracy of status determination and input into software. Views of Responsible Officials: There is no disagreement with the finding.

Corrective Action Plan

Segregation of Duties – Child Nutrition Cluster Recommendation: Our auditors recommend the District designate an individual to review accuracy of status determination and input into software. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: To address segregation of duties concerns within the Child Nutrition Cluster program, the District has implemented enhanced controls and designated the Director of Food Services to conduct independent reviews of all eligibility determinations for free and reduced-price meal benefits. This process is actively underway with positive results. The designated reviewer verifies accuracy and completeness of household applications, confirms correct income calculations and household size determinations, and reviews eligibility data input into our nutrition management software to confirm accurate recording of statuses. We have established a formal monthly review schedule with increased scrutiny during peak application periods, and these reviews have already identified and corrected several discrepancies that could have led to compliance issues. Documentation of reviews, including discrepancies and corrective actions, is maintained in program files for monitoring purposes. Since implementing this segregated review process, we have seen measurable improvements in eligibility determination accuracy, with fewer errors requiring correction and greater consistency in applying program rules. By separating initial determination from review and verification functions, we have created meaningful checks and balances that reduce error risks and prevent potential fraud. Additionally, we have implemented periodic training for all staff involved in the meal application process. These measures effectively strengthen segregation of duties within our Child Nutrition Cluster operations, enhance accountability, and ensure program integrity. Name of the contact person responsible for correction action: Lavesa Glover-Verhagen Planned completion date for corrective action: June 30, 2026

Categories

Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1169099 2025-004
    Material Weakness Repeat
  • 1169100 2025-004
    Material Weakness Repeat
  • 1169101 2025-004
    Material Weakness Repeat
  • 1169103 2025-005
    Material Weakness Repeat
  • 1169104 2025-005
    Material Weakness Repeat
  • 1169105 2025-005
    Material Weakness Repeat
  • 1169106 2025-005
    Material Weakness Repeat
  • 1169107 2025-006
    Material Weakness Repeat
  • 1169108 2025-006
    Material Weakness Repeat
  • 1169109 2025-006
    Material Weakness Repeat
  • 1169110 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 SPECIAL EDUCATION GRANTS TO STATES $392,302
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $355,098
84.041 IMPACT AID $330,975
93.778 MEDICAL ASSISTANCE PROGRAM $317,095
10.553 SCHOOL BREAKFAST PROGRAM $114,927
10.555 NATIONAL SCHOOL LUNCH PROGRAM $89,813
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $87,534
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $48,940
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $40,078
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $18,946
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $8,257
84.184 SCHOOL SAFELY NATIONAL ACTIVITIES $4,889
10.556 SPECIAL MILK PROGRAM FOR CHILDREN $3,053
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $1,959
84.425U EDUCATION STABILIZATION FUND $1,378
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $999