Finding Text
Federal Agency: United State Department of Education Federal Program Name: Title II, Part A – Supporting Effective Instruction State Grants Special Education Cluster (IDEA) Title I A – Grants to Local Educational Agencies Assistance Listing Number: 84.367 84.027, 84.173 84.010 Federal Award Identification Number and Year: S367A240047-2024 H027A240064-2024, H173A240070-2024 S010A240049-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2025 - 403619 - DPI - YIPPE - 342, 2025-403619-DPI-FLOW-341, 2025-403619-DPI-FLOW-341, 2025 - 403619 - DPI - FNC - 342, 2025-403619-DPI-ELIMG-348, 2025-403619-DPI-ELTAI-348, 2025-403619-DPI-PRESCH-347, 2025-403619-DPI-TI-A-141 Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: In accordance with 2 CFR 200.303(a), the District must establish and maintain effective internal control over the federal award that provides reasonable assurance that the District entity is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. In accordance with 2 CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Additionally, 2 CFR 200.403(g) requires that costs are adequately documented to be allowable under federal awards. Condition: During testing, instances were identified in which the semi-annual certifications utilized by the District to support time charged to federal awards completed and approved prior to the final claims. Title II, Part A – Supporting Effective Instruction State Grants (ALN 84.367) Three (3) of the 40 individuals selected for testing time was supported by a semi-annual certification that was not approved timely. The semi-annual certification was approved after the submission of the final reimbursement claim. This was not a statistically valid sample. Special Education Cluster (IDEA) (ALN 84.027, 84.173) Two (2) of the 40 individuals selected for testing time was supported by a semi-annual certification that was not approved timely. The semi-annual certification was approved after the submission of the final reimbursement claim. This was not a statistically valid sample. Title I-A – Grants to Local Educational Agencies (ALN 84.010) Three (3) of the 60 individuals selected for testing time was supported by a semi-annual certification that was not approved timely. The semi-annual certification was approved after the submission of the final reimbursement claim. This was not a statistically valid sample. Questioned costs: None Context: The District supports time charged to federal awards via semi-annual certifications which are approved by the grant administrator or the building principal. In order for a cost to be supported at the time of the final reimbursement, the semi-annual certifications should be approved by the grant administrator or the building principal. During the fiscal year under audit the collection and review of these certifications were delayed, resulting in some being collected after the final claim dates. Cause: From 2023 through 2025, the District experienced substantial turnover within the finance department, including management positions. Individuals in these roles lacked the necessary skills, knowledge, and experience to oversee day-to-day operations, resulting in delays in execution of controls and collection of required supporting time and effort reporting. Effect: Lack of timely collection and review of approved semi-annual could result in unallowable costs may be submitted for reimbursement. Repeat Finding: This is a repeat of prior year finding 2024-009 Recommendation: We recommend the District design and implement controls to ensure semi-annual time and effort certification are obtained and reviewed timely. Views of responsible officials: There is no disagreement with the audit finding.