Finding Text
2023 – 003
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
Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to non-procurement debarment and suspension regulations.
Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that three vendors were not suspended or debarred prior to the purchase.
Questioned costs: None.
Context: For the 2 vendors with purchases exceeding the threshold, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance.
Cause: The District did not retain documentation of their verification and documentation of the vendor’s status as not suspended or debarred with the Federal Government.
Effect: The lack of documentation over these compliance requirements provides an opportunity for noncompliance.
Repeat finding: This is a repeat of finding 2022-003.
Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships.
Views of responsible officials: There is no disagreement with the audit finding.