Finding Text
Federal Agency: United State Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553 and 10.555
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Numbers: 2023-155130-SB-546; 2023-155130-NSL-547
Award Period: 07/01/2022 – 06/30/2023
Compliance Requirement Affected: Suspension and Debarment
Type of Finding
Significant deficiency in internal control over compliance
Condition
District did not document procedures for verification of suspension and debarment of vendors.
Questioned Costs
None.
Criteria
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.
Context
The District did not review 1 of 2 vendors tested in our sample to ensure they were not suspended or debarred when initiating covered transactions in the current year.
Cause
The District does not have a policy or procedure in place to check if a vendor is debarred or suspended.
Effect
The District could contract with a vendor that has been suspended or debarred from receiving federal funds.Repeat Finding
No
Recommendation
We recommend the District use sam.gov listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements.
Views of Responsible Officials
There is no disagreement with the audit finding.