Finding 1169106 (2025-005)

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

AI Summary

  • Core Issue: The District failed to obtain the required number of price quotes for small purchases, violating procurement guidelines.
  • Impacted Requirements: Noncompliance with 2 CFR 200.320, which mandates at least two quotes for small purchases and proper documentation for formal procurement.
  • Recommended Follow-Up: Review and update procurement policies to ensure compliance, and implement controls to consistently document adherence to these policies.

Finding Text

2025-005 Procurement – 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: Material Weakness in Internal control over Compliance, Material noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Condition: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. Additionally supporting documentation regarding the bidding completed by the District’s purchasing cooperative was not obtained for vendor meeting formal procurement threshold per district purchasing policy. Questioned Costs: None Context: During audit testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent used towards the program. In our sample of two transactions subject to small purchase requirements we noted that the District did not retain documentation of an adequate number of price quotes for the one of the two transactions selected for testing. In our sample of one vendor subject to formal procurement threshold we noted that the supporting documentation regarding the bidding completed by the District’s purchasing cooperative was not obtained. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement. Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. Repeat Finding: 2024-005 Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials: There is no disagreement with the finding.

Corrective Action Plan

2025-005 Procurement – Child Nutrition Cluster Recommendation: Our auditors recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. Our auditors also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In response to strengthening procurement practices within the Child Nutrition Cluster, the District has undertaken and is implementing a comprehensive review and enhancement of policies and procedures to ensure full alignment with Uniform Guidance (2 CFR Part 200) and the District's Purchasing Policy. Following detailed analysis of current procurement practices, we have implemented key enhancements including standardized procurement documentation templates, enhanced vendor selection procedures ensuring competitive procurement methods are consistently applied, and improved record-keeping systems. We have strengthened procedures for obtaining and documenting price quotes, formal bids, and proposals in accordance with established thresholds, with additional controls ensuring all procurement transactions receive appropriate supervisory review and approval. Since implementing these improvements, we have observed more consistent adherence to procurement thresholds, better documentation of competitive selection processes, and increased transparency in vendor selection decisions. We have provided targeted training to Child Nutrition staff and business office personnel on federal procurement requirements, and staff feedback indicates stronger understanding of compliance obligations. We have implemented quarterly internal reviews to monitor compliance, and initial reviews show marked improvement in documentation quality and policy adherence. These proactive measures are creating a robust and transparent procurement framework for the Child Nutrition Cluster, ensuring consistent compliance with federal regulatory requirements and district policies while promoting accountability and fiscal responsibility. Name of the contact person responsible for correction action: Lavesa Glover-Verhagen Planned completion date for corrective action: June 30, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1169099 2025-004
    Material Weakness Repeat
  • 1169100 2025-004
    Material Weakness Repeat
  • 1169101 2025-004
    Material Weakness Repeat
  • 1169102 2025-004
    Material Weakness Repeat
  • 1169103 2025-005
    Material Weakness Repeat
  • 1169104 2025-005
    Material Weakness Repeat
  • 1169105 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