Finding 636125 (2022-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-12-18
Audit: 55305
Organization: Ashwaubenon School District (WI)

AI Summary

  • Core Issue: The District failed to verify the suspension and debarment status of all vendors before entering into contracts, which is a significant deficiency in internal control.
  • Impacted Requirements: This finding violates 2 CFR Section 200.214, which mandates that non-federal entities ensure vendors are not suspended or debarred before engaging in covered transactions.
  • Recommended Follow-Up: The District should revise contracts to include verification language and utilize resources like sam.gov or the ELPS listing to check vendor status annually or prior to transactions.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers ? 84.027, 84.173 Federal Award Identification Number and Year: 2022-050182-DPI-IDEA-FT-341, 2022-050182-DPI-IDEA-P-347 and Year 2021-2022 Pass-Through Agency: Wisconsin Department of Public Instruction Award Period: 7/1/21 ? 6/30/22 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria or Specific Requirements: 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 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 could not provide proof of verification of the suspension and debarment status of vendors before entering into services. Context: The District did not review 9 of 9 vendors tested in our sample to ensure they were not suspended or debarred when initiating covered transactions in the current year. Cause: The District did not follow their Federal Funds Suspension and Debarment Policy related to appropriate methods of verifying vendors are not suspended or debarred. Questioned Costs: None. Repeat Finding: No. Effect: The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation: We recommend the District include contract language which ensures vendor are not suspended or debarred as well as utilize 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. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with this finding and management has developed a plan to correct the finding.

Categories

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

Other Findings in this Audit

  • 59681 2022-003
    Significant Deficiency
  • 59682 2022-004
    Significant Deficiency
  • 59683 2022-004
    Significant Deficiency
  • 636123 2022-003
    Significant Deficiency
  • 636124 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States $757,647
93.778 Medical Assistance Program $295,678
84.010 Title I Grants to Local Educational Agencies $293,853
10.553 School Breakfast Program $231,243
10.558 Child and Adult Care Food Program $163,807
10.555 National School Lunch Program $146,972
59.075 Shuttered Venue Operators Grant Program $100,640
10.559 Summer Food Service Program for Children $76,508
84.367 Improving Teacher Quality State Grants $62,182
84.196 Education for Homeless Children and Youth $49,472
84.173 Special Education_preschool Grants $42,543
84.060 Indian Education_grants to Local Educational Agencies $32,250
84.424 Student Support and Academic Enrichment Program $27,726
84.048 Career and Technical Education -- Basic Grants to States $14,674
84.425 Education Stabilization Fund $7,797
84.365 Improving Teacher Quality State Grants $6,751
10.556 Special Milk Program for Children $3,864