Finding Text
2023 – 002
Federal Agency: U.S Department of Agriculture
Federal Program Name: Child Nutrition Cluster
Assistance Listing Numbers: 10.553, 10.555
Federal Award Identification
Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023
Pass-Through Agency: Wisconsin Department of Public Instruction
Pass-Through Number(s): 2021-454515-NSL-547
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance
and Other Matter
Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained.
Condition: During our evaluation of the District's procurement policies in effect for the year under audit, it was noted that the policy in force for part of the year did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. The policy was update during the year to comply with such requirements.
Questioned costs: None.
Context: The District's purchasing policy updated during the year to comply the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. Prior to this update, the District's purchasing policy was had not been updated for several years and did not include all necessary aspects to comply with Uniform Guidance.
Cause: The District did not complete its review and updating of the procurement prior to the beginning of year and the initiation of current contracts.
Effect: The District's purchasing policy in effect during part of the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procurement methods, micro-purchase and small purchase transactions.
Repeat finding: This is a repeat of finding 2022-002.
Recommendation: We recommend the District should review and update, as necessary, policies to ensure they fully comply with Uniform Guidance and any other applicable requirements.
Views of responsible officials: There is no disagreement with the audit finding.