Finding Text
Suspension and Debarment Federal District: U.S. Department of Education Federal Program Name: Special Education - Grants to States (IDEA, Part B) & Special Education - Preschool Grants (IDEA Preschool) Assistance Living Numbers: 84.027 & 84.173 Pass-Through District: Wisconsin DPI Pass-Through Numbers: 2022-402303-DPI-FLOW-341 & 2022-402303-DPI-PRESCH-347 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria Specific Requirement: 2 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, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and District adopting regulations, is not suspened or debarred or otherwise excluded from participating in the transaction. Condition: The District has an established written Uniform Guidance policy which includes policy and procedures related to suspension and debarment. The District has not consistently followed formal controls as outlined in the District policy related to ensuring suspension and debarment status was verified prior to entering into covered transactions with vendors. During the audit, CLA completed testing and verified that none of the vendors were suspended or debarred. Questioned Costs: None Context: There were four transactions that exceeded the $25,000 covered transaction threshold during the granting period. For three of the four vendors in our sample the District was unable to provide documentation related to suspension and debarment verification ensuring that the vendors were not suspended or debarred. Cause: The District did not consistently evaluate and document requirements to review vendors for suspension and debarment as required under Uniform Guidance requirements and the District's suspension and debarment policy. Effect: The District could enter into a covered transaction with a vendor that is suspended or debarred which violates compliance requirements. Repeat Finding: No Recommendation: We recommend the District review policies and procedures to ensure that they are following compliance requirements. We recommend the District use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements and implement controls to make sure this review is completed and documented prior to formalizing the contract. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the finding. Refer to the District's corrective action plan for additional information.