Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Elementary and Secondary School Relief Fund
Assistance Listing Number: 84.425D, 84.425U
Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021, S425U210044 Federal Award Date 12/6/2021 and 3/13/2020
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165, 2024-714508-DPI-LETRS-165
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR 200.334 states that "The recipient and subrecipient must retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to, financial records, supporting documentation, and statistical records." Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction.
Condition: The District is required to file an annual report for ESSER. The supporting documentation used to enter the data into the reporting portal was not maintained and there was no review of the data entered into the form by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes.
Questioned Costs: None.
Context: While performing audit procedures, it was noted that there was no review of the report completed by the finance director by someone else. The supporting documents used to complete the report was not retained by the District.
Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations.
Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties.
Repeat Finding: No.
Recommendation: We recommend the District review its grant reporting processes and implement internal controls to help ensure that there is adequate segregation of duties in regards to grant reporting including special reports and that all supporting documentation is maintained with the filed copy of the report.
Views of Responsible Officials: There is no disagreement with the audit finding.