Cedar Grove Belgium School DistrictLocal Government

2025 – 004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Education Federal Program Name: Special Education (IDEA Cluster) Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number: 2024-591029-DPI-FLOW-341, 2025-591029-DPI-PRESCH-347 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matter Condition: During our testing of small purchase procurement transactions greater than $500 it was noted they were not supported by an adequate number of quotes (at least two). In addition, during our testing of suspension and debarment, we identified two vendor contracts that were entered into that did not include language related to suspension and debarment. Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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. Question Costs: None Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor. Cause: The District did not follow their Federal Funds Procurement Policy and District controls did not properly document procurement, suspension and debarment requirements in accordance with Uniform Guidance. Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District’s Federal Funds Procurement Policy. We also recommend the District evaluate current procedures and controls, including segregation of duties, to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials: There is no disagreement with the finding.

Federal Agency: United State Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2023-591029-DPI-NSL-547 Award Period: 07/01/2022 – 06/30/2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matter Criteria or Specific Requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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. Condition: During our testing of procurement transactions of the program we noted that the District was not consistently following the procurement policy, specifically requirements related to small purchases. Small purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. In addition, during our testing of suspension and debarment, we identified two vendor contracts that were entered into that did not include language related to suspension and debarment. Questioned Costs: None Context: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In our sample of five procurement transactions subject to small purchase requirements we noted that the District did not retain documentation of an adequate number of price quotes for two vendors selected for testing. Additionally, in our sample of two suspension and debarment transactions, the District did not verify that either vendor was not suspended or debarred before entering into the transaction. Cause: The District did not follow their Federal Funds Procurement Policy and District controls did not properly document procurement, suspension and debarment requirements in accordance with Uniform Guidance. Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. The lack of documentation related to suspension and debarment could result in the District doing business with a suspended or debarred vendor.Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District’s Federal Funds Procurement Policy. We also recommend the District evaluate current procedures and controls, including segregation of duties, to ensure that policies are consistently followed and properly documented in accordance with District policies. View of Responsible Officials: There is no disagreement with the finding.

2022 ? 005 - Procurement Federal Agency: United State Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2022-591029-DPI-NSL-547 Award Period: 07/01/2021 ? 06/30/2022 Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least two). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Condition: During our testing of procurement transactions of the program we noted that the District was not consistently following the procurement policy, specifically requirements related to small purchases. Small purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Questioned Costs: None Context: During our testing of procurement transactions of the program we noted that the small purchases were not supported by an adequate number of quotes (at least two) to ensure the District is prudent with the monies used towards the program. In our sample of four procurement transactions subject to small purchase requirements we noted that the District did not retain documentation of an adequate number of price quotes for two vendors selected for testing. Cause: The District did not follow their Federal Funds Procurement Policy related to appropriate methods of procurement. Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Recommendation: We recommend the District review procedures to ensure that the District?s procurement policy is consistently followed. View of Responsible Officials: There is no disagreement with the finding.

2022 ? 006 ? Special Tests and Provisions ? Verification of Applications Federal Agency: United State Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2022-591029-DPI-NSL-547 Award Period: 07/01/2021 ? 06/30/2022 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria: The District is required to verify and support with documentation the current free and reduced price eligibility of households selected from a sample of applications that it has approved for free and reduced price meals as of October 1 and completed by November 15. Condition: The District did not retain workpapers to support that the special tests and provision to perform verification of free and reduced price applications was completed. Questioned Costs: None Context: The District has limited employees and does not have adequate segregation of duties over the grant management process to ensure that the documentation to support the verification process was retained. Cause: The District did not retain documentation and other information to support their procedures over the compliance requirements of the program. Effect: The District may have households that were not eligible for the status based on the documentation and other information obtained through the verification process. Recommendation: We recommend the District establish procedures and controls over the retention of verification documentation and other information obtained through the verification process. View of Responsible Officials: There is no disagreement with the audit finding.

2022 ? 007 ? Reporting Federal Agency: United State Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2022-591029-DPI-NSL-547 Award Period: 07/01/2021 ? 06/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria: Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a procedure. Condition: The claim forms submitted by the District are not reviewed and approved prior to submission. Accordingly, this does not allow for proper segregation of duties for internal control purposes over reporting compliance requirements. Questioned costs: None Context: The District has limited employees and does not have adequate segregation of duties over the grant management process. Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District?s operations. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of timely review of the grant claims. Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. View of Responsible Officials: There is no disagreement with the audit finding.

Condition: Management is responsible for the design, installation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system.The limited size of the District?s office staff prevents the ideal separation of functions. The Director of Business Services position is highly involved with the recording of daily activity in the District?s general ledger and is primarily responsible for general ledger accounting functions including recording of journal entries. In addition, while accounts payable and payroll processing are not the Director of Business Services primary responsibility, the position does have access to all phases of the District?s general ledger software which includes the ability to create new vendors in the accounts payable module and the ability to create new employees and adjust wage rates in the payroll module.Context: The size of the District and limited number of staff creates a weakness in internal control relative to segregation of duties.Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional.Cause: The lack of segregation of duties is due to the limited number of employees and the key role in which the Director of Business Services position serves in maintaining the District?s general ledger.Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties.Recommendation: We recommend that the Board of Education continue to monitor the transactions and the financial records of the District. We also recommend that the District continue to evaluate cost effective opportunities to improve the design of the internal control structure.Views of responsible officials: There is no disagreement with the finding.

Condition: During our testing of procurement transactions of the program we noted that the selection of vendors for food, dairy, and bakery supplies were not supported by an adequate number of quotes (at least 2) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended, or otherwise excluded.Context: During our testing of procurement transactions of the program we noted that the selection of a vendor was not supported by an adequate number of quotes (at least 2) to ensure the District is prudent with the monies used towards the program. The District did not have procedures in place to ensure a vendor was not debarred, suspended, or otherwise excluded.Criteria: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Additionally, Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment.Effect: Obtaining price quotes and proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes or proposals may cause the District to overpay for supplies or services. Additionally, not verifying that an entity is not debarred or suspended could result in entering covered transactions with debarred or suspended vendors.Recommendation: We recommend the District follow their procurement and suspension and debarment policy related to small purchases which includes obtaining price quotes from an adequate number of vendors (at least two), proposal policy for obtaining proposals from an adequate number of sources, and suspension and debarment policy for verifying vendors and maintaining this documentation.View of Responsible Officials: District will follow their Procurement and Suspension and Debarment policy for small purchases and proposals by obtain pricing quotes from a minimum of two vendors and maintain documentation.