Brodhead School District

Reference Number: 2025-004 Program Name: Child Nutrition Cluster Description: Eligibility Condition: During our testing, we noted that 2 of 12 applications were approved based solely on information contained in Step 2 of the application, regardless of whether the program name is an immediate eligible qualification for either free or reduced meals. Criteria: Per 7 CFR 245.6(a), the District must ensure all applications are complete, signed, and supported by adequate documentation prior to approval. Cause: Inadequate controls in place to ensure student meal applications are properly reviewed. Effect: Not properly reviewing applications reduces the accuracy of eligibility determinations and increases the likelihood that ineligible students receive free or reduced benefits. Questioned Costs: N/A – known and projected questioned costs did not exceed the $25,000 reporting threshold. Identification of a Repeat Finding: This is not a repeat finding. Auditors’ Recommendation: We recommend that the District review their procedures related to application review. The only programs that immediately qualify an applicant to skip income eligibility requirements are: 1) FoodShare, 2) W-2 Cash Benefits, or 3) Food Distribution Program on Indian Reservations. Views of Responsible Officials: See attachment for District’s corrective action plan.

Reference Number: 2025-005 Program Name: Special Education Cluster Description: Allowable Costs Condition: During our testing of six individuals, we noted that the District was unable to demonstrate that the amount of time charged to the grant was supported by adequate documentation for one support staff. Criteria: 2 CFR 200.430(i) requires that the District demonstrate the amount of time charged to the grant is at least the amount of actual time the position worked on the grant’s objectives. Cause: The District was unaware that this position required time and effort documentation. Effect: Without time and effort support for this position, the District may overcharge or undercharge the grant. Questioned Costs: $56,218. Identification of a Repeat Finding: This is not a repeat finding. Auditors’ Recommendation: We recommend that the District review the Allowable Costs for IDEA memo released by the Wisconsin Department of Public Instruction. Views of Responsible Officials: See attachment for District’s corrective action plan.

Reference Number: 2025-006 Program Name: Special Education Cluster Description: Procurement, Suspension and Debarment Condition: During our testing of procurement, the District did not retain documentation demonstrating the suspension and debarment status of two (2) vendors paid. While the District verbally stated that SAM.gov checks were performed, no evidence was available for examination. Criteria: 2 CFR 200.214 requires Districts to ensure, and retain evidence, that the verification process was complete. Verification can be documented through 1) a screenshot or printout from SAM.gov, 2) An official certification from the vendor, or 3) a written record the verification was completed. Cause: The District’s procurement policy does not formally state that retention of the search is required. Effect: The District can’t demonstrate compliance with federal procurement requirements. Questioned Costs: None. Identification of a Repeat Finding: This is not a repeat finding. Auditors’ Recommendation: We recommend that the District update their procurement policy to include that retention of the search is required. Views of Responsible Officials: See attachment for District’s corrective action plan.

Condition and Criteria: The size of the District?s administrative staff limits the duties that can be properly segregated. Cause: Limitations in staff size affect the District?s ability to have segregation of duties, especially in the cash receipts cycle. One individual is in charge of receiving, recording, and depositing all funds received by the District. Effect: The lack of segregation of duties could result in the possibility of undetected errors or irregularities. Identification of Repeat Finding: This is a repeat finding; see 2020-001. Recommendation: It is important for management to be aware of this condition and to realize that the concentration of duties and responsibilities in one or two individuals is not desirable from a control standpoint. Under these conditions, the most effective controls rest in management?s knowledge and monitoring of matters relating to the District?s financial affairs. View of Responsible Official: See corrective action plan.

Reference Number: 2020-001 Description: Segregation of Duties: Condition and Criteria: The size of the District?s administrative staff limits the duties that can be properly segregated. Cause: Limitations in staff size affect the District?s ability to have segregation of duties, especially in the cash receipts cycle. One individual is in charge of receiving, recording, and depositing all funds received by the District. Effect: The lack of segregation of duties could result in the possibility of undetected errors or irregularities. Identification of Repeat Finding: This is a repeat finding; see 2019-001. Recommendation: It is important for management to be aware of this condition and to realize that the concentration of duties and responsibilities in one or two individuals is not desirable from a control standpoint. Under these conditions, the most effective controls rest in management?s knowledge and monitoring of matters relating to the District?s financial affairs. View of Responsible Official: See corrective action plan.

Reference Number: 2019-003 Description: Procurement Policy Condition: 2 CFR part 215 requires the District to establish and follow a procurement policy when purchasing goods and services charged to the federal programs. Uniform Guidance requires that rate quotes are required from an adequate number of qualified suppliers for purchases ranging from $10,001-$250,000. Criteria: The District?s procurement policy states that the District does not have to obtain an adequate number of rate quotes for the following purchases: ? Textbooks, books, tapes, films, workbooks, educational kits and periodicals ? Professional services ? Replacement parts or maintenance contracts for existing equipment or mechanical systems ? CESA contracts ? Maintenance contracts of at least one year?s duration where the maintenance is to be performed on a routine or as needed basis on the specific equipment and shall include the additional cost of all repairs or replacement parts Uniform Guidance does not allow board policies to override the minimum requirements of obtaining an adequate number of rate quotes from qualified suppliers. Cause: The District?s board of directors passed a procurement policy that did not meet the minimum requirements of obtaining an adequate number of rate quotes from qualified suppliers for all purchases. Effect: The District may not be in compliance with the minimum requirements of Uniform Guidance. Recommendation: We recommend the District revise their procurement policy to be in compliance with the minimum federal requirements under 2 CFR part 215. Views of Responsible Officials: See Corrective Action Plan.

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