School District of West Allis- West Milwaukee, Et Al.

FINDING 2020-003- Federal ID Number, Program Name and State Agency 93.778 Medical Assistance Program, U.S. Department of Health and Human Services Award Amount - $1,086,054 Award Number ? N/A Criteria In order to bill Wisconsin Medicaid for School Based Services (SBS), the student must have an SBS identified on his or her IEP. Cost reimbursement is disallowed if the services are not specified or no IEP is obtained by the District. Condition/Context In a sample of 40 students, 2 students did not have an IEP for the 2018/2019 school year. The sample was not statistically valid. Cause The District did not obtain a proper IEP or did not remove students no longer enrolled. Questioned Costs $228 Effect The District is not following the provisions of the Medicaid program which may cause the District to receive more funding than the District is eligible for. Recommendation We recommend management ensure proper IEP documentation is obtained and maintained in accordance with Federal, State and local laws and regulations.

FINDING 2020-004 - Federal ID Number, Program Name and State Agency 10.553 / 10.555 / 10.559 Child Nutrition Cluster, U.S. Department of Agriculture Award Amount - $2,494,115 Award Number ? N/A Repeat of prior year finding 2019-005 Criteria 2 CFR 200.303 Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control design to reasonably ensure compliance with federal laws, regulations, and program requirements. To minimize the risk of errors, internal controls should be in place for all program requirements, including appropriate review and approval of reports. Condition During testing of reimbursement reports it was noted that there was no physical documentation of the review and approval of the reports. Cause The District currently does not have proper documented internal controls for review of reimbursement reports before being submitted to the state agency. Questioned Costs Could not be determined. Context When reviewing the support for monthly reimbursement requests it was noted that there was no documentation of a review/approval process. Effect Lack of effective documented controls over the review function could result in reports being submitted with errors. Recommendation The District should review its internal control procedures and consider adding a documented review and approval function.

FINDING 2019-005 - Federal ID Number, Program Name and State Agency 10.553 / 10.555 / 10.559 Child Nutrition Cluster, U.S. Department of Agriculture 84.184G Safe and Drug-Free Schools and Communities National Programs, U.S. Department of Education Award Amount - $3,163,407 and $618,861 Award Number ? N/A and S184G114015 Criteria 2 CFR 200.303 Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control design to reasonably ensure compliance with federal laws, regulations, and program requirements. To minimize the risk of errors, internal controls should be in place for all program requirements, including appropriate review and approval of reports. Condition During testing of reimbursement reports it was noted that there was no physical documentation of the review and approval of the reports. Cause The District currently does not have proper documented internal controls for review of reimbursement reports before being submitted to the state agency. Questioned Costs Could not be determined. Context When reviewing the support for monthly reimbursement requests it was noted that there was no documentation of a review/approval process. Effect Lack of effective documented controls over the review function could result in reports being submitted with errors. Recommendation The District should review its internal control procedures and consider adding a documented review and approval function.

FINDING 2019-007 - State ID Number, Program Name and State Agency 84.027 / 84.173 Special Education Cluster (IDEA), U.S. Department of Education 84.184G Safe and Drug-Free Schools and Communities National Programs, U.S. Department of Education Award Amount - $2,231,649 and $618,861 Award Number ? 2019-406300-DPI-IDEA-FT-3412019-406300-IDEA-PS-347 and S184G140115 Repeat of prior year finding 2018-007 Criteria To minimize the risk of improper payment or errors in payments, internal controls should be in place for all program compliance requirements, including appropriate review and approval of authorized wages on an annual basis to ensure the charges are accurate and allowable. Condition / Context During testing of payroll expenditures, 12 out of 40 individuals tested in the Special Education Cluster (IDEA) and 12 out of 29 in the Safe and Drug-Free Schools and Communities National Program did not have authorized wages that were approved by a supervisor. The sample was not statistically valid. Cause Procedures requiring supervisor review and approval of authorized wages were not communicated and enforced within the District. Questioned Costs Could not be determined. Effect An employee may be compensated with an unauthorized wage. Recommendation Management should ensure review and approval controls are in place for all authorized wages within the District.

FINDING 2019-008 - Federal ID Number, Program Name and State Agency 93.778 Medical Assistance Program, U.S. Department of Health and Human Services Award Amount - $1,445,152 Award Number ? N/A Criteria In order to bill Wisconsin Medicaid for School Based Services (SBS), the District is required to have a signed and dated ?Consent to Bill Wisconsin Medicaid for Medically Related Special Education and Related Services? (M-5 form) from the parent or guardian of a student with an IEP before claims can be submitted. Condition/Context In a sample of 40 students with an IEPs billed through Medicaid, 26 students did not have a signed M-5 form on file. The sample was not statistically valid. Cause The District did not obtain or keep a signed M-5 form on file for the noted students. Questioned Costs Could not be determined. Effect The District is not following the provisions of the Medicaid program which may cause the District to receive more funding than the District is eligible for. Recommendation We recommend management ensure signed consent forms are obtained and maintained in accordance with Federal, State and local laws and regulations.

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