Finding 512854 (2024-003)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2024-12-03
Audit: 330620
Organization: Sheboygan Area School District (WI)

AI Summary

  • Core Issue: The District failed to complete required suspension and debarment checks before engaging vendors for covered transactions.
  • Impacted Requirements: Noncompliance with 2 CFR 200, which prohibits contracting with suspended or debarred parties.
  • Recommended Follow-Up: Review and enhance policies and procedures to ensure compliance with suspension and debarment requirements.

Finding Text

2024-003 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: 07/01/2023 – 06/30/2024 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, 2023-004. 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.

Corrective Action Plan

Suspension and Debarment This is no disagreement with the finding. Management immediately began to review policies and procedures.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 512855 2024-003
    Significant Deficiency Repeat
  • 512856 2024-003
    Significant Deficiency Repeat
  • 512857 2024-003
    Significant Deficiency Repeat
  • 512858 2024-003
    Significant Deficiency Repeat
  • 512859 2024-003
    Significant Deficiency Repeat
  • 512860 2024-003
    Significant Deficiency Repeat
  • 512861 2024-003
    Significant Deficiency Repeat
  • 512862 2024-003
    Significant Deficiency Repeat
  • 512863 2024-003
    Significant Deficiency Repeat
  • 512864 2024-003
    Significant Deficiency Repeat
  • 1089296 2024-003
    Significant Deficiency Repeat
  • 1089297 2024-003
    Significant Deficiency Repeat
  • 1089298 2024-003
    Significant Deficiency Repeat
  • 1089299 2024-003
    Significant Deficiency Repeat
  • 1089300 2024-003
    Significant Deficiency Repeat
  • 1089301 2024-003
    Significant Deficiency Repeat
  • 1089302 2024-003
    Significant Deficiency Repeat
  • 1089303 2024-003
    Significant Deficiency Repeat
  • 1089304 2024-003
    Significant Deficiency Repeat
  • 1089305 2024-003
    Significant Deficiency Repeat
  • 1089306 2024-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.425D Education Stabilization Fund $3.87M
93.778 Medical Assistance Program $1.42M
10.553 School Breakfast Program $1.12M
10.555 National School Lunch Program $459,709
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $409,846
84.287 Twenty-First Century Community Learning Centers $281,880
10.558 Child and Adult Care Food Program $262,474
84.365 English Language Acquisition State Grants $212,146
84.424 Student Support and Academic Enrichment Program $146,687
10.559 Summer Food Service Program for Children $93,717
84.048 Career and Technical Education -- Basic Grants to States $92,279
84.173 Special Education Preschool Grants $57,772
84.010 Title I Grants to Local Educational Agencies $52,813
84.196 Education for Homeless Children and Youth $36,906
10.185 Local Food for Schools Cooperative Agreement Program $36,728
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $20,649
84.027 Special Education Grants to States $16,527
84.425U Education Stabilization Fund $7,000
84.427W Congressionally Directed Spending�rehabilitation Services and Disability Research $4,607