Finding Text
2025-003 Suspension & Debarment Federal Agency: U.S. Department of Agriculture, U.S. Department of Agriculture Federal Program Names: Child Nutrition Cluster, Special Education Cluster (IDEA) Assistance Listing Numbers: 10.553, 10.555, 10.559, 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-595271-DPI-SB-SEVERE-546, 2024-595271-DPI-NSL-547, 2024-595271-DPI-SFSP-586, 2024-595271-DPI-FLOW-341, CCEIS-Unknown-341, 2023-595271-DPI-ES3-342, 2024-595271-DPI-ES3-342, 2024-595271-DPI-WCCA-343, 2024-595271-DPI-PRESCH-347 Award Periods: 07/01/2024 – 06/30/2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal 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 nonprocurement 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). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: While the District has policies and procedures relating to suspension and debarment, they were not completed before entering into a covered transaction. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors in accordance with the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The District did not consistently follow the policy and procedures that are currently in place. Effect: The District is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes, 2024-004. Recommendation: We recommend the District review the policies and procedures and enhance as necessary to ensure suspension and debarment requirements are met. View of Responsible Officials: There is no disagreement with the finding.