Finding Text
Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-375628-DPI-SB-546, 2022-375628-DPI-NSL-547 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Compliance Requirements: Procurement Criteria or Specific Requirement: 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 business manager is responsible for preparing and reviewing procurement transactions related to the Child Nutrition Cluster. For some transactions, there was no review or proper procedure such as obtaining multiple quotes from a number of vendors and there was no control in place to review a vendor on the Sam.gov or other listing to see if they were suspended or debarred from receiving federal funds. Questioned Costs: None. Context: One out of eight micro-purchase transactions and two of six small purchase or proposal transactions tested had documented review and approval for the purchase. The District also did not have documented internal controls to ensure that the vendors were not suspended or debarred from receiving federal funds prior to. In addition, the District did not obtain price comparisons as required by District policy for two procurement transactions out of the five such transactions. Cause: Due to the limited staff size at the District, the majority of the procurement process the responsibility of the business manager with minimal oversight by other positions in the District. Due to this organization structure, there is not proper segregation of duties in place to allow for full review, approval, and verification that all procurement requirements were followed. Effect: The District could procure with vendors who are suspended or debarred or not allow themselves proper review of competition that may cause them to overspend on an item or service. Repeat Finding: No Recommendation: We recommended that the District implement a review process over the procurement requirements and establish controls over suspension and debarment related to the grant programs during the fiscal year. The District should also review its procurement policy to ensure that the thresholds within the policy match current federal requirements. Views of Responsible Officials: There is no disagreement with the audit finding.