Finding 45419 (2022-002)

Significant Deficiency

Requirement

Questioned Costs

Year

2022

Accepted

2023-01-01

Audit: 45998

Organization: School District of La Crosse (WI)

Auditor: Cliftonlarsonallen LLP

AI Summary

Core Issue: The District failed to check if vendors were suspended or debarred before contracting, risking noncompliance with federal regulations.
Impacted Requirements: Compliance with procurement rules under the Child Nutrition Cluster, specifically regarding contracts over $25,000.
Recommended Follow-Up: The District should update its policies to ensure proper checks for vendor eligibility and maintain compliance with suspension and debarment requirements.

Finding Text

2022-002 Child Nutrition Cluster ? Suspension & Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Federal CFDA: 10.553, 10.555, & 10.559 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2022-322849-DPI-SB-546, 2022-322849-DPI-SB-SEVERE-546, 2022-322849-DPI-NSL-547, 2022-322849-DPI-SK_NSLAE-561, 2022-322849-DPI-SFSP-561 Award Period: September 1, 2021 - June 30, 2022 Type of Finding: Significant deficiency in internal control over compliance Compliance Requirement: Procurement, Suspension & Debarment Criteria: Non-federal 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 non-procurement 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. Condition: The District did not maintain documentation that a search for suspension and debarment was performed for select vendors within the food service program. Questioned costs: None Context: Of the five sampled vendors, none of them had a review of suspension and debarment over procurement. Cause: The District did not have a procedure in place to perform a search for suspension and department associated for vendors with cumulative procurement transactions in excess of the $25,000 threshold. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat finding: No Recommendation: We recommend that the District review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, & 10.559 Recommendation: We recommend that the District review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While the Coulee School Nutrition consortium RFP requires vendors to include a debarment certification statement with each bid, the School District of La Crosse Supervisor of Finance has not consistently made it a practice to request verification of debarment status for all vendors. Debarment was last checked for the school nutrition program primary vendors, Reinhart Foods, and Prairie Farms Dairy, in 2019 when the last Prime Vendor bid contract was processed. The verification process consisted of the Supervisor of Finance requesting that her Administrative Assistant check debarment on vendors utilizing the Sam.gov website prior to approving purchase orders that exceeded $25,000. Debarment checks on the school nutrition vendors in question were missed because there were multiple purchase orders processed for these vendors that were each under the $25,000 threshold. Name(s) of the contact person(s) responsible for corrective action: Davita Jo Molling, Supervisor of Finance Planned completion date for corrective action plan: July 1, 2022

Other Findings in this Audit

45420 2022-003

Significant Deficiency
45421 2022-002

Significant Deficiency
45422 2022-003

Significant Deficiency
45423 2022-002

Significant Deficiency
45424 2022-003

Significant Deficiency
45425 2022-002

Significant Deficiency
45426 2022-003

Significant Deficiency
45427 2022-002

Significant Deficiency
45428 2022-003

Significant Deficiency
621861 2022-002

Significant Deficiency
621862 2022-003

Significant Deficiency
621863 2022-002

Significant Deficiency
621864 2022-003

Significant Deficiency
621865 2022-002

Significant Deficiency
621866 2022-003

Significant Deficiency
621867 2022-002

Significant Deficiency
621868 2022-003

Significant Deficiency
621869 2022-002

Significant Deficiency
621870 2022-003

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
10.553	School Breakfast Program	$1.42M
93.778	Medical Assistance Program	$797,608
93.243	Substance Abuse and Mental Health Services_projects of Regional and National Significance	$655,847
10.555	National School Lunch Program	$345,323
84.027	Special Education_grants to States	$336,095
10.559	Summer Food Service Program for Children	$206,711
14.218	Community Development Block Grants/entitlement Grants	$200,000
84.367	Improving Teacher Quality State Grants	$199,901
84.424	Student Support and Academic Enrichment Program	$146,584
84.048	Career and Technical Education -- Basic Grants to States	$57,817
84.196	Education for Homeless Children and Youth	$39,747
84.010	Title I Grants to Local Educational Agencies	$32,305
84.365	English Language Acquisition State Grants	$29,755
84.173	Special Education_preschool Grants	$9,727
15.659	National Wildlife Refuge Fund	$5,886
84.060	Indian Education_grants to Local Educational Agencies	$1,948
84.425	Education Stabilization Fund	$1,657