Finding 592320 (2022-006)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-26

AI Summary

  • Core Issue: The District failed to maintain proper procurement documentation and verify vendor compliance with suspension and debarment regulations.
  • Impacted Requirements: Non-compliance with 2 CFR Section 320.318(i) and 2 CFR Section 200.214 regarding procurement records and vendor eligibility.
  • Recommended Follow-Up: Review and update procurement policies, ensure all staff understand compliance requirements, and implement controls for verifying vendor status.

Finding Text

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Federal Award Identification Number and Year: N/A Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-373304-DPI-SB-546, 2022-373304-DPI-NSL-547 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Section 320.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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: The District is part of a consortium composed of multiple school districts that designated one member district to handle procurement, suspension and debarment for all consortium members? food service programs. District policy requires District approval of the contracts after consortium finishes the proposal process and selects the prime vendors for the year. Questioned costs: None Context: While there is a consortium lead who is responsible for procurement compliance, the District did not verify this was properly completed, maintain procurement documentation for its files, and obtain District Administrator and Board approval of contracts as required by District policy. This was not done for both procurement transactions in our sample. District also did not obtain documentation from the consortium lead regarding suspension and debarment status for the prime vendors used prior to approving contracts for the school year. This was not done for the one vendor in our sample. Cause: The District was not aware they needed to document controls ensuring District policy was followed and that it needed to maintain documentation regarding compliance when the consortium handled the process. Effect: Procurement contracts may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status. Views of responsible officials: There is no disagreement with the audit finding.

Categories

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

Other Findings in this Audit

  • 15874 2022-006
    Significant Deficiency
  • 15875 2022-007
    Material Weakness
  • 15876 2022-006
    Significant Deficiency
  • 15877 2022-007
    Material Weakness
  • 15878 2022-006
    Significant Deficiency
  • 15879 2022-007
    Material Weakness
  • 592316 2022-006
    Significant Deficiency
  • 592317 2022-007
    Material Weakness
  • 592318 2022-006
    Significant Deficiency
  • 592319 2022-007
    Material Weakness
  • 592321 2022-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $166,399
10.553 School Breakfast Program $79,429
93.778 Medical Assistance Program $50,975
32.009 Emergency Connectivity Fund Program $39,995
84.027 Special Education_grants to States $36,687
10.555 National School Lunch Program $31,899
84.010 Title I Grants to Local Educational Agencies $21,709
84.367 Improving Teacher Quality State Grants $12,255
84.424 Student Support and Academic Enrichment Program $10,000
84.173 Special Education_preschool Grants $4,159
84.048 Career and Technical Education -- Basic Grants to States $2,750